July 18, 2015

U.S. Department of Transportation

Federal Aviation Administration Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations.

Dear Madam, Sir,

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, WestLAND Group, Inc. (WestLA ND) an operator of the GeoBlu Surveyor 800 Unmanned Aircraft System (“UAS” or “GeoBlu”), s eeks and exemption from the Federal Aviation Regulations (FAR’s) listed below and as di scussed in Annex A.

The regulations from which the exemption is request ed are as follows:

14 C.F.R. 21

14 C.F.R. 45.23 14 C.F.R. 45.29 (f) 14 C.F.R. 91.9(b)(2) 14 C.F.R. 91.109(a)

14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203(a) (1) & (b) 14 C.F.R. 91.319(a)(1) 14 C.F.R. Subpart E (91.401 – 91.417)

Annex A discusses each rule listed above and explai ns why exemptions pursuant to the proposal set forth in this letter are appropriate, provide an eq ual equivalent level of safety, and are in the publ ic

interest.

The requested exemption would authorize WestLAND co mmercial operations using the GeoBlu for mapping and survey applications for oil pipelines a nd electrical towers as well as perform precision aerial surveys that consist of still photographs an d video taken by onboard cameras. GeoBlu takes aseries of high-quality, still digital images that a re used to produce precision digital point clouds,

triangulated models, and contour maps of the survey the area. Applications for these UAS devices and associated data processing functions include ma pping, inspections and professional surveying. Use of the Geo blue for aerial surveys reduces the need to operate conventional aircraft for the same purpose and provides a very high quality image ry at a fraction of the cost of surveys using conventional aircraft. These savings result in enh ance efficiency and productivity for the active affected activities, as well as environmental benef its.

Operations under the exemption will be subject to s trict operating requirements and conditions to ensure at least an equivalent level of safety to cu rrently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by section 333.

As described more fully below, the requested exempt ion would authorize commercial operations of aerial surveys using the GeoBlu, which at 1.7 pound s is small in size. The GeoBlu will be operated

under controlled conditions at low altitude and air space. It will have automated control features, as described below. The GeoBlu also will be operated by an individual who has passed and FAA approved ground training exam and a required manufa ctures training program for the UAS. The airspace in which the UAS will operate will be disc losed to the FAA in advance.

Westland Group respectfully submits that because th e small, unmanned aerial vehicle the GeoBlu will be used in lieu of comparatively hazardous ope rations now conducted with fixed wing and rotary conventional aircraft. The FAA can have con fidence that the operations will achieve at least an equivalent level or greater level of safety.

Approval of this exemption would thereby enhance sa fety and fulfill the Secretary of Transportation's (the FAA administrator’s) responsi bilities under section 333(c) of the Reform Act to "establish requirements for the safe operation o f such aircraft systems in the national airspace system."

The name and address of the applicant are:

Rich Josenhans with a copy to: Blanca Hoff meier Westland Group Inc. Westland Group Inc. 11023 Eucalyptus Street 25020 Avenue Stan ford #10 Rancho Cucamonga, CA 91730 Santa Clarita, CA 91355 Phone: (909) 989-9789 Phone: (661) 705- 1051 Fax: (909) 989-9660 Email: bhoffmeier@westlandgroup.net

Email: rjosenhans@westlandgroup.netAPPLICABLE LEGAL STANDARDS UNDER SECTION 333

Airworthiness of the GeoBlu

A critical element of the exemption application inv olves evidence of the airworthiness of the GeoBlu. GeoBlu is a small and ultralight platform that performs precision aerial mapping missions, using the onboard GPS and the related fig ht management software that allows the operator to plan safely and efficiently a mission i n 3-D and then monitor it in real time. Using the implanted camera, protected by a Velcro envelope, t he GeoBlu takes a collection of high definition still images and /or video that are used later to g enerate maps and contour lines of the survey area.

The four main characteristics of the GeoBlu are as follows: a)Very light weight.

The GeoBlu is so small and ultra-light that the ope rator can easily take-off and land on almost any surface. Its low impact energy in case of a contro lled emergency landing, also significantly reduces the risk of hazardous situations. The propellers of the Geo blue are detachable and made a flexible plastic with no sharp or hard edges and almost no i nternal strengthening structure.

b) Electric powered. The GeoBlu is battery powered.

c) Semi automatic flight. The artificial intelligence incorporated within the GeoBlu auto pilot systems continuously analyzes

data from the Inertial Measurement Unit from the on board GPS and takes care of all the aspects of the flight under the supervision of the operator.

d) Option for manual control. Additionally, the GeoBlu provides an override capab ility that allows the operator to take manual actions during the flight (Go to Home, Go Land, Hol d and Resume the mission) and also suspend the automated operations and take the manual contro l of the aircraft should it become necessary to respond to you to emergent circumstances, using the remote controller provided with the system.

Mandatory Operating Conditions

Grant of the exemption to Westland Group for the Ge oBlu will be subject to the following mandatory conditions, which are based upon operatin g conditions set forth for operation of UAS by commercial entities pursuant to certifications of a uthorization, with additional restrictions:

• Unmanned Aircraft will weigh less than 55 lbs, incl uding payload

• Visual Line of Sight (VLOS) only; the unmanned airc raft must remain within the VLOS of the operator or visual observer• At all times the small unmanned aircraft must remai n close enough to the operator for the

operator to be capable of seeing the aircraft with vision and aided by any device other than

corrective lenses

• Small unmanned aircraft may not operate over any pe rsons not directly involved in the operation

• Daylight-only operations (official sunrise to offic ial sunset, local time)

• Must yield right-of-way to other aircraft meant or unmanned

• May use visual observer but not required

• First person view camera cannot satisfy see and avo id requirement but can be use as long as requirement is satisfied in other ways

• Maximum airspeed of 100 mph or 87 knots.

• Maximum altitude of 500 feet above ground level

• Minimum weather visibility of 3 miles from control station

• No operations are allowed in Class A (18,000 feet & above) airspace

• Operations in Class B, C, D and E airspace are allo wed within the required ATC permission

• Operations in class G airspace are allowed without ATC permission

• No person may act as an operator or VO for more tha n one unmanned aircraft operation at

one time

• No careless or reckless operations

• Requires preflight inspection by the operator• A person may not operate a small unmanned aircraft is if he or she knows or has reason to

know of any physical or mental condition that would interfere with the safe operation of a

small UAS

Operator requirements

Westland respectfully proposes that operate a requi rement should take into account the characteristics of the particular UAS.

• Pilots of small US would be considered operators

• Operators would be required to:

o Pass an initial aeronautical knowledge test at an F AA approved knowledge testing

center

o Be vetted by the Transportation Security Administra tion

o Obtain an unmanned aircraft operator certificate wi th small UAS rating, similar to existing pilot airman certificates, never expires

o Pass a recurrent aeronautical knowledge test every 24 months

o Be at least 17 years old

o Make available to the FAA upon request the small US for inspection or testing and any associated documents or records required to be kept under the proposed rule

o Report an accident to the FAA within 10 days of any operation that results in injury or property damage

o Conduct a preflight inspection to include specific aircraft and control station systems check to ensure the small US essay for operation

Public Interest

By moving surveying and mapping functions from a gr ound based human enterprise to the aerial platform of the GeoBlu, WestLAND will have the abil ity to collect an enormous amount of data in

a fraction of the time that would be consumed in a ground based effort. The flight mission can be preplanned maximizing the survey effort into minute s instead of days on even the smallest of projects. As the project size increases, the savin gs to both WestLAND and the client will increase exponentially. Information collected by t he GeoBlu will change the entire decision making process and work flow. Instead of days to c ollect and process the ground-based data WestLAND can collect GeoBlu preliminary data and be gin to provide intelligent data to our clients at a near real-time rate of information exchange. I mproving data collection by moving to the UAS as the survey platform allows her clients to stand with our operator and begin the process of analysis at the very moment the data is collected.

The cost to purchase and maintain the GeoBlu is nom inal in comparison to that of a traditional manned aircraft. A major advantage of the low opera tional expenses is that WestLAND can provide these ariel acquisition services at a much lower cost to the customer while remainingcompetitive and profitable, thereby contributing to economic growth and stability at a local, state

and federal level.

Due to its unique, lightweight and compact design, the GeoBlu can be assembled and deployed in less than 10 minutes after arriving on site. It ca n perform its mission effectively and efficiently a nd literally land at your feet. The data from the mis sion can begin to be processed immediately. All of these factors prove to be a huge benefit to the consumer, especially in the case of natural disaste r or emergency situation.

Conclusion

Authorizing WestLAND to contact surveying and mappi ng of oil pipelines and electric towers using GeoBlu under the conditions specified herein would bring immediate and significant safety improvement to the aerial surveying industry. West land’s UAV would be used to conduct tower and pipeline inspections in the matter that provide s at least an equivalent level of safety compared to the current regulatory structure that applies to manned aircraft. Conventional tower inspections require a human being to climb a tower to visually observe and analyze the physical to status of the tower, and related equipment. Remote pipeline insp ections require humans to hike dangerous terrain and cliffs to get closer to a pipeline to d o visual inspections or use traditional very costly manned aircraft inspections.

Given that the GeoBlu is compact, and the restricte d, controlled environment, within which WestLAND will operate, (remote areas where non-acce ssible pipelines and electrical towers are located), WestLAND falls squarely within the type o f operations that the FAA intended be authorized pursuant to Section 333. WestLAND’s pro posed operations are similar to the operations authorized under Section 333 Grants, including seve ral nearly identical types of operations. Accordingly, WestLAND requests that FAA grant it an exemption without delay.

Respectfully submitted,

Blanca Hoffmeier WestLAND Group, incANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

SHOWING UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

.

WestLAND Group, requests an exemption from the foll owing regulations as well as any additional regulations that may technically apply t o the operation of the GeoBlu.

14 C.F.R. Part 21, Subpart H: Airworthiness Certifi cates, 14 C.F.R. § 91.203(a)(1).

Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled “Airworthiness Certificates”, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91. 203(a). Given the size of GeoBlu and the limited operating area associated with its utilizat ion, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H in order to achieve or exceed current safety level.

Such an exemption meets the requirements of an equi valent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requi rement for an airworthiness certificate, upon consideration of the size, weight, speed, operation al capability, and proximity to airports and populated areas of the UAS involved. Analysis of th ese different criteria demonstrates that the GeoBlu operated without an airworthiness certificat e, under the conditions proposed in that exception, will be at least as safe, or safer, than a conventional aircraft with an airworthiness

certificate.

14 C.F.R. § 45.23(b) & 14 C.F.R. § 45.29(f): Displa y of marks; Size of marks.

“When marks include only the Roman capital letter “ N” and the registration number is displayed on limited, restricted or light-sport category airc raft or experimental or provisionally certificated aircraft, the operator must also display on that ai rcraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches no r more than 6 inches high, the words “limited,” “restricted,” “light-sport,” “experimental,” or “pr ovisional,” as applicable.”

The GeoBlu has no entrance to the cabin, cockpit or pilot station on which a suggested word can be placed. Given the size of the UAV, two inch let tering will be impossible. The word “PROVISIONAL” will be placed on the forward fuselag e in compliance with 12C.F.R. 45.29(f) 14. C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be not granted allowing commercial operation of the GeoBlu without an airworthiness certificate, no standard w ill exist for airworthiness of GeoBlu.

An equivalent level of safety will be achieved by i nsuring compliance with the GeoBlu manuals prior to each flight.14 C.F.R. § 91.9(b)(2): Civil aircraft flight manua l, marking, and placard requirements

.

This regulation provides that no person may operate an aircraft unless a current, approved flight

manual is in the aircraft. WestLAND assumes that th e intent of this requirement is to ensure that flight manual information is available to the aircr ew while operating the aircraft. WestLAND requests an exemption to the requirement since the aircraft is not only too small to carry documentation, the documentation would not be avail able to the crew.

The equivalent level of safety will be achieved by keeping a hardcopy of the flight manual in the GeoBlu transportation box.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instru ction

.

The regulation provides that “No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully function ing dual controls.”

Flight instruction will be accomplished through an elaborated training program, using the first simulation mode of the flight management software G eoBlu. T he equivalent level of safety during the training will be achieved by the manufac turer providing the training as outlined in Exhibit 2 and through the use of experienced and qu alified operators familiar with the GeoBlu.

14 C.F.R. § 91.121 – Altimeter settings

.

This section requires that 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 below 18,000 feet MSL to:

“The current reported altimeter setting of a statio n along the route and within 100 nautical mile of the aircraft;

If there is no station within the area prescribed i n paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; In the case of an aircraft not equipped with a radi o, the elevation of the departure airport or an appropriate altimeter setting availab le before departure.”

To provide an equivalent level of safety, the Geo Blu autopilot calculates the reference altitude(ground level) will the on-board GPS during the pre -flight tests. The GPS and barometer data are

merged with respect to their respective precisions. The GPS provides reliable information to correct potential barometric bias, while rapid vari ations in altitude are detected through the barometer. Hence, barometric bias induced by envir onmental factors is rejected.

14. C.F.R. § 91.151(a): Fuel Requirements for Fligh t in VFR Conditions

.

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first poi nt of intended landing and to fly after that for at

least 30 minutes.

Given the area of operation for the GeoBlu, WestLAN D believes that an equivalent level of safety is already achieved with the specific procedure pre venting the GeoBLu to accept a takeoff order as the battery level is below a given value. Moreo ver, the GeoBlu has integrated low and critical battery level warnings and implemented a “return to Home” (and “Go Land”) actions in these

situations.

14. C.F.R. § 91203(a) & (b): Carrying Civil Aircraf t Certification and Registration.

This regulation provides as follows:

“No person may operate a civil aircraft unless it h as an appropriate and current airworthiness

certificate.

“No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a spec ial flight authorization is issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.” [Italics added]..

The GeoBlu is very light in weight, (much less than the accepted 55lbs). As such, there is no ability or place to carry the certification and reg istration documents or to display them on the UAS. In addition, there is no pilot or passengers o n board the aircraft.

To obtain an equivalent level of safety and meet th e intent of 91.203, GeoBlu proposes that documents deemed appropriate for this aircraft by t he FAA will be co-located with the operator at the ground control station in the GeoBlu box and av ailable for inspection upon request.

14 C.F.R. Subpart E (91401 – 91.417- Maintenance, P reventative Maintenance, and

Alterations

.

The regulation provides that the operator is primar ily responsible for maintaining the aircraft in an airworthy condition, including compliance with Part s 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be “approved for return t o service by a person authorized under 43.7” after maintenance and inspection. Section 91.409(a)(2) re quires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been acco mplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

WestLAND proposes that the maintenance of the GeoBl u will be accomplished by the

owner/operator according to the maintenance manual, provided by GeoBlu.

An equivalent level of safety will be achieved beca use the GeoBlu is small in size, it is not a complex mechanical device, it will carry no externa l payload, and it will operate only in restricted predetermined areas. Moreover, the operating is the person most familiar with the aircraft and is

best suited to maintain the aircraft in an airworth y condition and to ensure an equivalent level o f safety. Finally, before every flight, the GeoBlu runs automatically a sequence of pre-flight test to make sure that every sensor and every critical p art is running properly. If a problem is detected, the GeoBlu will not be able to be switch ed-on and a message error is displayed on the main screen of the GeoBlu monitor. The operator can then refer to the maintenance manual to troubleshoot this issue. Several parts of the Geo Blu are easily interchangeable (propellers), which allows the operator to make sure the propellers and propulsion systems are always airworthy when

a mission is initiated.