1

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060



### UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _________________

In the Matter of Petition for Exemption of:

GA UAV Services LLC

For an Exemption from the requiremen ts of the

Code of Federal Regulations Sections

Concerning Operation of an Unmanned Aircraft System

Pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012

Submitted July 15th , 2015 by:

GA UAV Services LLC

Matthew Beebe , Founding Partne r

415 Freyer Drive

Marietta, GA 30060

Telephone: ( 770 ) 362

- 4080

Fax: ( 000 ) 000

- 0000

Beebe_matthew@yahoo.com2

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 

## Contents

I. Petitioner’s Description

II. Relevant Statutory Authority

III. Qualifications for Appr oval under Section 333 of the Reform

Act

IV. Training and Proposed Operations

V. Regu lations from which Exemption is R equested

VI. Public Interest

VII. Privacy

VIII. Publication Summary

IX. Conclusion3

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 

## I. Petitioner’s Description

GA UAV Services LLC is a new company offering multiple UAV services from aerial

inspection, aerial videography for real estate /construction, building/tower inspection,

and manufacturing facility aerial inspection. Our staff has over 6 years of flying

experience in large RC based fixed wing single and multi

- engine aircraft and also over 2

years flying multi ro tor and single rotor aircraft. GA UAV Services plan to offer services

for filming and analysis of video captured results for our clients.

Currently our staff is o ngoing P rivate Pilot training through local flight school in

Kennesaw GA at McCullum International Airfield. Our objective is to complete this

training and achieve our FAA licensing in the early fall of this year.

GA UAV services has participated in many educa tional programs over the last 6 years

in educating the public of the fun of flying RC aircraft within the AMA approved facilities

in the US. We have participated in education of the youth, general public and

parti ci pated within man y local news reports to educate our community of the fun and

safe uses of RC and UAV base aircraft.

GA UAV Services has nurtured a strong commitment to safety in regards to its

employees and the general public. GA UAV Services wishes to continue its ever

evolving, specialized services with an exemption, pursuant to Section 333 of the

Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (the

Reform Act), from Federal Aviation Regulations (FARs) identified below, allowing

commercial operations of small unman ned aircraft systems (UAS).

The petitioner’s contact information is as follows:

GA UAV Services LLC

Matthew Beebe , Founding Partner

415 Freyer Drive

Marietta, GA 30060

Telephone: ( 770 ) 362

- 4080

Fax: ( 000 ) 000

- 000

beebe_matthew@yahoo.com4

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 

## II. Relevant Statutory Authority

This petition for exemption is submitted to fulfill Congress’ goal in passing Section 333

(a) through (c) of the Reform Act. Congress has directed the FAA “to safely accelerate

the i ntegration of civil unmanned aircraft systems into the national airspace system.”

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to consider

whether certain UAS may operate safely in the National Airspace (NAS) before

completion of the formal UAS rulemaking, based on the following considerations:

 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 the visual line of sight of t he

 operator.

Pursuant to 49 U.S.C. § 44701 (f), the FAA Administrator has authority to grant

exemptions if the request is found to be in the public interest.



## III. Qualifications for Approval under Section 333 of the Reform

Act

The proposed operations i n this petition for exemption qualify for expedited approval

under Section 333 of the Reform Act. Each of the statutory criteria and other potential

relevant factors are satisfied.

The proposed operations would permit the use of small and relatively inexp ensive UAS

under controlled conditions in airspace that is: (1) identified; (2) predetermined, and; (3)

controlled as to access. The use of UAS would also provide a higher level of safety than

exists when rope access technicians are asked to gain access, a nd is therefore, in the

public interest.

The UAS to be used weighs less than fifty

- five (55) pounds, including payload.

Operation of the aircraft will be limited to use during ideal weather conditions (good

visibility, no precipitation, and winds under 15 knots). The aircraft has the ability to hover

and move in the horizontal and vertical planes simultaneously. With fixed wing

operations we will operate our fixed wing aircraft at slow speed to maintain safe

operations. The UAS will not be operated at spee ds greater than 27 knots. The UAS will

be operated within visual line of sight (VLOS) of the pilot in command (PIC) with the aid

of a visual observer (VO).5

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 

## IV. Training and Proposed Operations

A. Training

GA UAV Services has established a trainin g program for the PIC and VO. The PIC

will be an FAA licensed airman with at least a private pilot certificate and a third class

medical certificate. The VO will assist the PIC in all UAS operations from

the onset of training and hold considerable knowledg e in the use and maintenance

of UAS.

The PIC training will involve 25 hours of UAS flight training. This training will

include 250 flight cycles (takeoffs and landings) and 10 of the 25 hours will

involve the DJI Mutli rotor that will be used in GA UAV ’ p roposed UAS

operations. All pilot training will be documented in the GA UAV Services Pilot and

Aircraft Logs

.

B. Proposed Operations

Proposed UAS operations by GA UAV Services would be limited to certain projects

whose location is suited for the safe use of the UAS. The use of the UAS will be

evaluated prior to and specifically for each project’s vicinity.

GA UAV Services seeks to use UAS in its ever

- evolving inspection services. The

requested exemption would allow GA UAV Services to provide inspection se rvices

to consumers interested in aerial data capture using a small, technologically

advanced UAS for:

 Buildings

 Chimneys

 Bridges

 Dams

 Real Estate

 Industrial/Manufacturing facilities

 Other infrastructure

The proposed operations will occur over private an d/or controlled access property

with the owner’s prior consent. In the event operations will be conducted over

public lands, a pre

- determined area will be identified and all permissions will be

acquired from official personnel and affected organizations. T he area for operations will

be pre

- determined, limited, and controlled as to access. All operations will follow

parameters set forth in the GA UAV Services Flight Operations Manual as follows:

 With an FAA granted exemption, GA UAV Services will obtain a n Air

Traffic Organization (ATO) issued Certificate of Waiver or Authorization6

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 (COA) for each UAS operation. In accordance with the COA, GA UAV will request a

Notice to Airmen (NOTAM) not more than 72 hours in advance, but no less than 48

hours prior to th e operation.

 All UAS operations will involve a minimum of two (2) GA UAV

personnel, consisting of the PIC and VO.

 Flights will only occur in favorable weather conditions during daylight hours. Weather

affecting operations include, but are not limited to, precipitat ion, wind above 15 knots,

limited visibility due to fog or clouds, and lightning.

 All UAS flights will remain in visual line of sight (VLOS) at all times.

 When flights occur within 5 nautical miles of an airport reference point, GA UAV

Services will ob tain a letter of agreement with the airport’s management and conduct

operations in accordance with a NOTAM, as required by the approved COA.

 UAS flights will be terminated at 2 0 minutes or when battery power is reduced to

40 %, whichever comes first.

 Th e UAS will be programmed to not fly above 400 feet above ground level (AGL).

 When necessary, the UAS may also be programmed to not fly outside of a

designated, controlled area.

 PIC will be an FAA licensed airman with a private pilot license and a third

- class

medical certificate.

 The UAS will weigh less than 55 pounds including payload.

 The UAS will not operate at speeds over 27 knots.

 The UAS has the capability to hover in place, and move in the horizontal and vertical

planes simultaneously.

 The fixed wing aircraft will be flown as traditional fixed wing aircraft with climb,

descend, level flight characteristic such as what a traditional man ned aircraft would be

safely flown.

 Th e PIC will routinely reference the GA UAV Services UAS Flight Checklist during

operations to ensure the maintenance and airworthiness of the aircraft, and to ensure

general safety during flight operations.

 GA UAV Services will follow the UAS manufacturer ’s maintenance, overhaul,

r eplacement, inspection, and life limit requirements.

C. Unmanned Aircraft System

GA UAV ’ proposed UAS operati ons would use a DJI multirotor aircraft with a Zenmuse

camera gimbal, both manufactured by DJI. The Zenmuse camera gim bal will hold a

GoPro Hero camera for capturing photographs and video. Also the larger Zenmuse

gimbal will hold a regular 3 5 MM camera

, small form factor infared cameras and some

small format video camcorders

.

The follo w i ng is a list of DJI Multi Rotor’s that will be part of GA UAV aircraft inv e ntory

and will be known and documented in further explanations as “DJI multi rotor” and/or

“fixed wing UAV”

 DJI Phantom 2 and Vision 27

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060  DJI Inspire 1

 DJI S900

 DJI S1000

 DJI S1000+

 Quantum 600 with DJI NAZA V2 or A2 Flight Controllers

 Fixed wing UAS aircra ft less than 55 pounds with payload utilizing flight control

systems

The aforementioned DJI Multi rotor’s utilizes the DJI Naza

- M V2 and A2 flight control

system. The aircraft has the capability to hover, and move in the vertical and horizontal

plain sim ultaneously. The aircraft is equipped with a global positioning system (GPS),

Inertial Measurement Unit (IMU), and Compass that work in unison to stabilize the

aircraft and render safety features. The aircraft can be programmed to not fly above 400

feet AG L and to not fly outside of a pre

- determined flight zone. These systems will also

initiate the failsafe function. If the aircraft looses the signal from the transmitter, the GPS

system will automatically initiate the failsafe mode and fly the aircraft back to a pre

determined location and land automatically.

The fixed wing UAS will utilize a similar flight controller but it will be manufactured by 3D

robotics in comparison to DJI and will provide similar functionality with inertial

measurement, GPS and com pass capabilities to aid in flight operations.



## V. Regulations from which Exemption is R equested

GA UAV Services seeks exemption of the following FAR’s

A. 14 CFR Part 21, Subpart H: Airworthiness Certificates and 14 CFR §

91.203(a)(1)

B. 14 CFR § 61.56 Flight review

C. 14 CFR § 61.113: Private pilot privileges and limitations: Pilot in command

D. 14 CFR § 91.7(a): Civil aircraft airworthiness

E. 14 CFR § 91.119(c): Minimum safe altitudes

F. 14 CFR § 91.121: Altimeter settings

G. 14 CFR § 91.151(a): Fuel requirements for flight in VFR conditions (day)

H. 14 CFR §§ 91.405(a): Maintenance required; 91.407(a)(1): Operation after

maintenance, preventative maintenance, rebuilding, or alteration; 91.409(a):

Inspections; 91.417 (a)(b): Maintenance records A. 14 CFR Part 21; Subpart H:

Airworthiness Certificates and 14 CFR §91.203(a)(1)

GA UAV Services requests an exemption from 14 CFR Part 21, Subpart H, which

establishes the procedures for attaining airworthiness certificates required by 14 CFR §

91.203(a)(1). The Reform Act allows the FAA to exempt aircraft from the requirement8

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 of an airworthiness certificate in consideration of the size, weight, speed, operational

capability, and proximity to airports and populated areas of the particular UAS.

Equivalent Level of Safety

The UAS to be operated is the DJI Multi rotor’s , weighs less than 55 pounds including

payload s , carries no pilot or passengers, carries no flammable liquid fuels, and operates

within a pre

- determined flight zone. Furthermore, the PIC and V O will determine the

airworthiness of the DJI Multi r otor aircraft prior to each flight, by adhering to safety

guidelines set forth in the DJI Multi R otor User Manual , the GA UAV Services Flight

Operations Manual

, and the GA UAV Services UAS Flight Checklis t

.

B. 14 CFR § 61.56: Flight review

GA UAV Services requests exemption from 14 CFR § 61.56, which subjects the pilot in

command (PIC) to flight review requirements consisting of one (1) hour of flight time in

an aircraft in which the PIC is rated on his or her pilot certificate and one (1) hour of

ground training. The flight review requirements set forth in 14 CFR § 61.56 would have

little relevance to the safe operation of the small UAS intended for use in GA UAV ’

operations.

Equivalent Level o f Safety

An equivalent level of safety will be achieved by following the training procedures in the

DJI Multi R otor User Manual and the GA UAV Services Flight Operations Manual.

The GA UAV Services Flight Operations Manual requires the PIC to be subject t o

test, or currency flights, in between and leading up to official operations to ensure skills

and safety. Currency flights will occur on a monthly base, as needed, and consist of at

least one (1) hour of flight with the DJI Multi R otor and/or fi xed wing a ircraft , including at

least 10 take

- offs and landings.

C. 14 CFR § 61.113: Private pilot privileges and limitations: Pilot in command

GA UAV Services requests an exemption from 14 CFR § 61.113, limiting private pilots

to non

- commercial operations. However , the UAS will not carry pilots, passengers, or

any living thing and be restricted to a flight zone that is predetermined and controlled as

to access. The risks associated with the UAS operations are far diminished from the

risks associated with commercial operations envisioned by 14 CFR Part 61, when

drafted.9

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 Equivalent Level of Safety

Proposed UAS operations will obtain an equivalent level of safety, as the aircraft will

carry no living thing on board. The level of safety provided by the requirements s et forth

in the GA UAV Services Flight Operations Manual exceeds that provided by a single

individual holding a commercial pilot certificate operating a conventional aircraft.

D. 14 CFR § 91.7(a) Civil aircraft airworthiness

GA UAV Services requests an exe mption from 14 CFR § 91.7(a), which requires that

civil aircraft be in airworthy condition to be operated. Since the DJI M ulti R otor has no

airworthiness certificate, there is no regulatory standard for determining the

a irworthiness of the UAS.

Equivalent Level of Safety

In accordance with 14 CFR § 91.7(b), the PIC will determine whether the UAS is in a

condition for safe flight by complying with procedures in the DJI multi rotor User

Manual

, the GA UAV Services Flight Operations Manual , and the GA UAV Se rvices

UAS Flight Checklist

.

E. 14 CFR § 91.119(c) Minimum safe altitudes

GA UAV Services requests an exemption from 14 CFR § 91.119(c), which establishes

minimum safe altitudes “over other than congested areas,” in which an aircraft below

500 feet AGL m ay not operate closer than 500 feet to any person, vessel, vehicle, or

structure. In order to provide the intended inspection services, the UAS will be operated

below 500 feet AGL and closer than 500 feet to persons, vessels, vehicles, and

structures.

Equ ivalent Level of Safety

Operation of the UAS is safer than traditional aircraft due to its small size, lightweight,

lack of flammable fuel, and limited speed. Additionally, no flight will occur without the

permission of the property owner or local officia ls. With advanced notice given, all

property owners and affected persons will be aware of all UAS operations. The UAS will

be operated in a restricted and controlled area. Under no circumstances will the UAS be

operated so close to persons, vessels, vehicl es, or structures as to present an undue

hazard10

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 F. 14 CFR § 91.121: Altimeter settings

GA UAV Services requests an exemption from 14 CFR § 91.121, which states that

when operating below 18,000 feet MSL, aircraft not equipped with a radio shall set an

a ltimeter to the elevation of the departure airport or an appropriate altimeter setting

available before departure. An exemption is required because the UAS is not equipped

with a user configurable barometric altimeter. With our experience in the AMA Amate ur RC flying, we will not exceed a flight altitude of greater than 400 AGL, and our flight

estimates will be at this altitude for most of our future flights

Equivalent Level of Safety

Complying with the pre

- flight procedures in the DJI Multi R otor User Manual and

verifying the GPS altitude before each flight will provide an equivalent level of safety.

During f light, the DJI multi rotor provides an Above Ground Level (AGL) reading in

relation to its takeoff location. The altitude will be closely monitored during flight,

keeping the UAS below 400 feet AGL, ensuring operations at safe altitudes.

Furthermore, the U AS will remain within VLOS of the PIC and VO at all times. Our

participation within the AMA we had to maintain safety procedures at a national level

and local field such as not flying over the pit area which would be similar to not flying

over populated o r congested areas of the public/persons.

G. 14 CFR § 91.151(a): Fuel requirements for flight in VFR conditions (day)

GA UAV Services requests an exemption from 14 CFR § 91.151(a), which states than

no person may begin a flight unless there is enough fuel to fly to the first point of

intended landing and, assuming normal cruising speed to fly after that for at least 30

minutes. The battery powering the DJI multirotor aircraft provides approximately 25

minutes of total flight time. It is therefore impossibl e for the UAS to meet the

requirement of this section.

Equivalent Level of Safety

Planning all flights with the intent to land after 2 0 minutes or at 40 % battery power

remaining, whichever comes first, will provide an equivalent level of safety.

Additi onally, unlike traditional aircraft, the UAS will always be within VLOS and have

no significant transit time to or from the landing area. GA UAV Services will only operate

the UAS in day time VFR conditions within VLOS in good weather conditions.11

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 H. 14 C FR §§ 91.405(a) Maintenance required; 91.407(a)(1) Operation after

maintenance, preventative maintenance, rebuilding, or alteration; 91.409(a)

Inspections; 91.417(a) and (b) Maintenance records

GA UAV Services requests an exemption from the maintenance an d inspections

requirements of 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a), and 91.417(a) and (b).

These regulations apply to maintenance of aircraft holding an airworthiness certificate,

which the DJI multi rotor’s does not have. Therefore an exemption is required.

Equivalent Level of Safety

An equivalent level of safety will be achieved by ensuring that the UAS is in working

order prior to initiating flight, performing required maintenance, and keeping a log of any

maintenance performed. All maintenance and inspections will be performed in

accordance with the DJI Multirotor User Manual and the GA UAV Services Flight

Operations Manual

.



## VI. Public Interest

An exemption for GA UAV Services to use UAS commercially would help to fulfill

Congress’ goal in ass essing whether certain UAS may operate safely in the NAS.

The exemption is in the public interest as it offers a safer and more cost

- effective option

for inspecting buildings, chimneys, bridges, dams, Industrial/Manufacturing f acilities,

real estate, and other infrastructure than other traditional methods

. It provides a safer

methodology for taking aerial videography by not flying traditional aircraft carrying

flammable fuel over the public areas or congested areas.

The use of a small, relatively inexpensive, and lightweight UAS offers a safer alternati ve

to industrial rope

- access methods. Such methods put human climbers on these

structures, exposing them to the inherent risks of working at extreme heights.

A small UAS is also a safer alternative method to the use of articulating boom cranes for

under

- br idge inspections. These methods subject human operators to the risk of falls

from height, entrapment due to mechanical failures, and the dangers of moving traffic

nearby. Furthermore, these methods require coordination to close traffic lanes, reducing

traf fic flow. Vehicles, including the boom truck and associated work vehicles, are parked

in lanes directly adjacent to moving traffic putting public motorists and workers at

increased risk.

Utilization of UAS reduce the cost of producing the videography by reducing costs for

fuel, rental of expensive manned aircraft, and provides a community advantage in that

the utilization of the UAS’s is more cost effective to individuals than the traditional

method of manned aircraft.12

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 Lastly, UAS operations would prov ide a higher level of safety than inspection services

for buildings, chimn eys, bridges, dams, industrial/ manufacturing facilities, real estate,

and other in frastructure using manned aircraft. Such operations put pilots and

c rewmembers at risk. Lightweight and powered by batteries, the UAS provides a much

safer option than that of a large and extremely heavy aircraft laden with highly explosive

fuel.



## VII. Privacy

As mentioned above, all flights will occur in an area that is pre

- determined, limited, and

controlled as to access. Privacy will not be an issue where flights occur over private

property. In the event flights will occur over public lands, prior permission will be

requested from all official personnel and organizations relevant to the pre

- determi ned

flight zone prior to commencement of flight mission

.



## VIII. Publication Summary

The petitioner, GA UAV Services LLC , seeks exemption from the following rules to

commercially operate UAS in the National Airspace for inspections of: (1) buildings, (2)

chimneys, (3) bridges, (4) dam s, (5) other infrastruct ure, (6) real estate , (7)

Industrial /manufact uring facilities and operations, or any other aerial based videography

or photography use for producing video or images.

14 CFR Part 21, Subpart H: Airworthiness Certificate s and 14 CFR §

91.203(a)(1)

14 CFR § 61.56 Flight review

14 CFR § 61.113: Private pilot privileges and limitations: Pilot in command

14 CFR § 91.7(a): Civil aircraft airworthiness

14 CFR § 91.119(c): Minimum safe altitudes

14 CFR § 91.121: Altimeter settin gs

14 CFR § 91.151(a)(1)(2): Fuel requirements for flight in VFR conditions (day)

14 CFR §§ 91.405(a): Maintenance required; 91.407(a)(1): Operation after

maintenance, preventative maintenance, rebuilding, or alteration; 91.409(a):

Inspections; 91.417 (a)( b): Maintenance records13

GA UAV Services LLC, 415 Freyer Drive Marietta, GA 30060 

## X. Conclusion

GA UAV Services LLC respectfully submits this request for expedited exemption under

Section 333 of the Reform Act. Given the small size of the UAS, the willingness of

GA UAV Services to gain all necessary permissio ns, and the commencement of clear

and well planned operations and maintenance programs, the commercial, UAS use by

GA UAV Services causes no threat to the general public or others using the National

Airspace.

________________________ Submitted July 15t h , 2015 by:

GA UAV Services LLC

Matthew Beebe , Founding Partner

415 Freyer Drive

Marietta GA, 30060

Telephone: ( 770 ) 362

- 4080

Fax: ( 000 ) 000

- 0000

Beebe_matthew@yahoo.com