m Engineering 

Surveying 

Testing & 

Operations 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

August 12, 2015 

~ c . ~; ~ J 

Re: Exemption Request under Section 333- Small UAS 

j( .·. 

123 West Front Street 

Traverse City, Michigan 49684 

231 946 5874 13 

231 946 3703 C!B 

Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a 

mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. 

Section 333(a) states that the FAA "shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the (comprehensive) 

plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by 

section 334 of this Act." In Section 332(b)(1 ), The Petitioner "GFA, Inc. (Gourdie-Fraser, 

Inc.)", hereafter referred to as GFA, proposes the following exemptions and meets all 

requirements to permit FAA approval of commercial UAS operations. The proposed 

exemption, if granted, would allow Petitioner to conduct commercial operations of small 

unmanned aircraft systems ("UAS") meeting or exceeding all of the operational and safety 

requirements Congress has set forth in Section 333. 

Petitioner is a professional engineering/surveying consulting firm that plans to use the unique 

capabilities of Unmanned Aerial Systems to more safely and efficiently offer a multitude of 

services, including: 

• Aerial surveying 

• Real estate evaluations 

• Construction site inspections and monitoring 

• Infrastructure/utility monitoring and inspection 

• Educational and research operations 

• Project-related aerial photography /videography 

(a) The name and contact information of the applicant are: 

GFA, Inc. (Gourdie-Fraser, Inc.) 

123 West Front Street 

Traverse City, Michigan 49684 

Point of Contact: Phil Case, P.S. 

Email: phil®gfa. tc 

(231) 946.5874 

DUNS: 006566640; sam.gov CAGE Code: 48891 
• 

Engineering 

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123 West Front Street 

Traverse City, Michigan 49684 

231 946 5874 a 

231 946 3703 mJ 

(b) The specific section or sections of 14 CFR from which exemption is sought: 

i. 14 CFR 21 

ii. 14 CFR 36 

iii. 14 CFR 45.29 

iv. 14 CFR 61.23 

v. 14 CFR 61.113 

vi. 14 CFR 91.9 

vii. 14 CFR 91.103 

viii. 14 CFR 91.119 

ix. 14CFR91.151 

x. 14 CFR 91.203 

xi. 14 CFR 91.405, 91.407, 91.409, 91.417 

(c) The extent of relief sought is for the duration of the Grant of Exemption, unless 

otherwise specified. The reason to seek the relief is as follows: 

I. 14 CFR 21 

a. The petitioner requests relief from 14 CFR part 21. The UAV is a small 

rotorcraft weighing less than 10 pounds during operation. The UAV 

maximum speed is 33 mph (28 knots) and the operating area will be limited 

to remote or impassable locations where vehicular traffic is non-existent or 

controlled. The PIC will maintain VFR Rules flying at no more than 400 feet 

and will operate the UAV during the day in line-of-sight so as not to create 

a hazard to users of the National Airspace System or the Public or pose a 

threat to national security. 

II. 14 CFR 36 

a. The Petitioner requests relief from any associated noise certification and 

testing requirements of part 36. As a note, according to the manufacturer's 

specifications, the UAV operates below 40db within 50 meters. 

Ill. 14 CFR 45.29 

a. The Petitioner request relief from the size requirements under this section 

due to the size limitations of the UAV. We propose to use marks as large as 

possible on the UAV as well as keep registration information with the PIC 

during operation and a digital copy of all registration information stored on 

the UAV. 

IV. 14 CFR 61.23 

a. The Petitioner requests relief from this section because the PIC and the YO 

will be operating the UAV wfth no passengers and no payload on board and 

therefore should not be held to the same medical standard as a commercial 

pilot. 
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V. 14CFR61.113 

a. The Petitioner currently does not have commercial pilot licenses and 

requests relief from 14 CFR part 61.113. The flight is only incidental to the 

proposed business or employment and the aircraft does not carry 

passengers or property for compensation or hire. 

VI. 14CFR91.9 

a. Relevant materials shall be kept in a location accessible to the PIC in 

compliance with the regulations. A digital copy of all necessary materials 

shall be stored on board the UAV. 

VII. 14 CFR 91.103 

a. In regards to 91.103(b), the UAV will not be operated within any Class B, C, 

or D airspace; but, the PIC will follow all other applicable pre-flight actions 

including reviewing weather, flight battery requirements, landings, and 

takeoff distances and aircraft performance data before initiation of flight. 

VIII. 14CFR91.119(c) 

a. The Petitioner requests relief from this section because PIC will ensure the 

UAV is operated in controlled environments outside of populated areas 

away from public and traffic; avoiding of areas which are depicted in 

"yellow" on VFR charts, as well as obtaining and assessing information 

regarding congested areas from the local Flight Standards District Office 

(FSDO) and avoiding areas of congestion. The UAV will not be operated 

within 500 feet of vehicles or objects in open areas. The Petitioner requests 

that if barriers or structures are present that can sufficiently protect nonparticipating persons from the UAV or debris in the event of an accident, 

the PIC may operate closer than 500 feet to persons afforded such 

protection. The operator will ensure that nonparticipating persons remain 

under such protection. 

IX. 14CFR91.151 

a. The Petitioner requests exemption from this section due to the maximum 

flight time available from this UAV. The UAV total flight time is limited to 

25 minutes and therefore the PIC would not be able to meet the minimum 

standards and still conduct the inspections. The UAS is equipped with a 

visual battery indicator that displays the battery levels at all time. 

b. Additionally, the UAS has a visual alarm that indicates when the battery 

reaches a state of 20% battery life, or approximately 7 minutes of flight 

time. These indicators, coupled with pilot awareness and the emergency 

return-to- station setting will supply ample time to land the UAV safely in 

the event of low battery. 
Engineering 

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Ope5etions 14 CFR 91.203 

123 West Front Street 

Traverse City, Michigan 49684 

23L946 58748 

231 946 3703 (I 

a. The Petitioner requests relief from 14 CFR 91.203 as the appropriate 

airworthiness certificate does not exist for this UAS. Additionally, the 

certificate cannot be displayed in the aircraft due to the size and physical 

structure of the UAV. 

XI. 14 CFR 91.405,407, 409, 417 

a. The Petitioner requests relief from 14 CFR 91.405, 407, 409, and 417 The 

above-cited regulations require, in general, aircraft owners and operators 

to inspect the aircraft " ... 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." These regulations apply to aircraft with an Airworthiness 

Certificate. Therefore, these sections are not applicable to this UAS. 

Operators will adhere to requirements located within the operations 

manual. 

(d) The reasons why granting this request would be in the public interest; that is, how 

it would benefit the public as a whole: 

a. Personnel Safety 

i. GFA, Inc. provides survey services to many major utility companies and 

is the as-needed surveyor the US Army Corps of Engineers Detroit 

District. Construction sites, dam sites and utility inspection sites are 

areas of high risk for data collection and travel. With the help of UAS 

more complete site inspections can be performed while minimizing the 

risk to the life and safety of employees. 

b. Access to remote or unreachable areas 

i. Segments of geographical features (sensitive dunes, bluffs, wetlands), 

construction sites, dams, farms, pipelines, towers, power lines, and 

bridges may currently be or become unreachable, partially obscured, or 

impracticable for inspection by conventional means, such as physically 

walking the line, or utilizing airplane or helicopters for inspections. 

Access to assets can also be partially or completely blocked by 

environmental singularities, such as vegetation growth, or blocked by 

mechanical means such as vehicle accidents, new construction, or road 

maintenance. The use of our UAV will ensure access to remote or 

impassable areas on an as-needed basis as well as during or after 

uncontrolled singular events. 

c. Cost Effectiveness 

i. Currently, multiple personnel consisting of agency officials, employees 

and/or contractors are often required to conduct field inspections on 

large projects over vast amounts of terrain in order to ensure public 

safety and meet regulatory requirements. Inspections can require a 
Engineering 

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substantial amount of person-hours over days or weeks at a time due to 

terrain and accessibility issues. Factoring in engineering, planning Et 

scheduling, safety meetings, mileage, recovered man-hours, potential 

down time due to injury, potential worker's compensation savings, and 

the intangible consideration of keeping employees injury-free, the 

current system of inspecting these assets becomes cost-prohibitive. UAV 

inspections in select areas are more time efficient, safer and more 

practical than the conventional methods for conducting these 

inspections - particularly in the event of a natural disaster such as 

storms or floods. Our UAV inspections will free up otherwise occupied 

employees, and provide a more economic approach to the traditional 

inspection, thus lowering operational costs. Lower overhead for 

corporations could lead to end-user savings such as decreased utility 

bills. 

ii. In addition, it creates a visual record of the construction process that 

may be referred to later should further construction or changes be 

required in the flown area. 

(e) The reasons why granting the exemption would not adversely affect safety, or how 

the exemption would provide a level of safety at least equal to that provided by 

the rule from which the exemption is sought: 

a. The petitioner states that the unmanned aircraft (UA) to be operated under 

this request is less than 25 lbs. fully loaded, flies at a speed of no more than 33 

mph (28 knots), 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 POH. The craft the Phantom 2 Vision Plus Quad-rotor 

manufactured by DJI. The Phantom 2 Vision Plus Quad-rotor system includes a 

GPS system, full autonomous autopilot capabilities, telemetry and manual 

ground control. 

In addition, the DJI Phantom 2 Vision Plus aircraft has integrated safety 

features built into the design of the UAS, as described in the POH, to ensure 

the safety of persons and property within and surrounding the limited operating 

area. In the event of a communication loss in manual control, the UAS 

switches to GPS control and return to its takeoff coordinates to perform a 

"FailSafe Landing" within the Security Perimeter. It will also have the 

capability to abort a flight in the event of unpredicted obstacles or 

emergencies. 

Petitioner's UAS's will be identified by serial numbers, registered in 

accordance with 14 C.F.R. Part 47, and have identification (N-Numbers) 

markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings will be as 

large as practicable. 

b. The aircraft will be operated with both a PIC and a ground-based Visual 

Observer (YO) in accordance with FAA Policy N 8900.227 Section 14, 
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Operational Requirements for UAS. Operations will be conducted in remote or 

inaccessible regions with the permission of the land owner; and all required 

permits will be obtained from state and local government before operation. 

The UAV will not be operated within 500 feet of vehicles or objects in open 

areas, unless barriers or structures are present that can sufficiently protect 

nonparticipating persons from the UAV or debris in the event of an accident. 

The PIC will file a Notice to Airmen (NOT AM) providing location and a 

date/time for each operation and a VFR Flight Following, if necessary. 

c. The aircraft will not be operated over urban or populated areas; at air shows or 

over an open-air assembly of people; over heavily trafficked roads; or within 

five nautical miles of an airport or heliport. If planned operations occur within 

five miles of Commercial Services Airport as defined by the FAA, the operator 

must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations. This COA will also 

require the operator to request a Notice to Airman (NOT AM) not more than 72 

hours in advance, but not less than 48 hours prior to the operation. 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. Flight operations will be limited to day, visual 

meteorological conditions and the aircraft will remain within visual line of sight 

of the PIC at all times. 

d. This exemption will provide a greater level of safety so that provided by the 

rule from which the exemption is sought due to the current nature of 

conducting inspections in remote regions. Because UAS flights are not currently 

authorized for commercial use, methods for inspecting remote assets are 

limited to pedestrian or helicopter operations. Where helicopter operations are 

not feasible due to environmental or mechanical obstructions, and or Structural 

elements, utilizing the UAV will provide a safe alternative to the inherent 

dangers of walking through these regions to conduct the required inspections. 

The small size, extreme maneuverability and zoom capabilities on the camera 

allow for a safe, unimpeded inspection of critical infrastructure assets. 

(f) Summary to publish in the Federal Register: 

a. The rule from which exemption is sought 

i. GFA, Inc. seeks exemption under §333 of the FAA Modernization and 

Reform Act of 2012 (Public Law 112-95) from 14 CFR 21; 14 CFR 36, 

45.23; 45.27, 45.29; 61.23; 61.113; 91.9(b) (2); 91.103(b); 119(c); 

91.151 (a); 91.203(a)&(b); 91.405(a); 91.407(a) (1 ); 91.409(a) (2); 

91.417(a)&(b) 
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Traverse City, Michigan 49684 

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b. A brief description of the nature of the exemption sought 

i. GFA, Inc. requests an exemption under Section 333 of the FAA Modernization 

and Reform Act of 2012 for commercial flight of its UAS. GFA provides aerial 

survey and inspection focused on construction and technical applications. With 

approval of this petition, GFA will utilize our UAS to perform inspections, 

progress reports, surveying, mapping and other related services focused on the 

construction industry. Proposed operations will be performed in full compliance 

with aviation safety regulations. As per 14 CFR §11.81, this petition for 

exemption is prepared and filed in accordance with regulation to request 

exemptions from the Federal Aviation Regulations pertaining to operation of a 

UAS so that operations can be commercially completed in accordance to all 

applicable FARs that would pertain to a small UAS. 

(g) Any additional information, views or arguments available to support request 

I. Argument 

GFA is requesting this exemption because we strongly believe in the continuous 

improvement of safety measures to protect our field personnel from the inherent 

dangers of the work environment, as we seek to improve and develop the investigation 

and data collection methods in the technical perspective of the construction 

processes. As mentioned above, we are proud to work on behalf of major utility 

providers and the US Army Corps of Engineers in evaluating and supporting critical 

infrastructure throughout the Great Lakes basin. The use of Unmanned Aircraft 

Systems affords us a great opportunity to continue delivering a high-quality work 

product in a safe and efficient manner. Through adopting and utilizing UAS 

technological advancements within these fields, we are unlocking the potential to 

create a safer workplace, ensure regulatory requirements are exceeded, and build 

inspection data with which we can improve and protect the infrastructure of crucial 

industries. We look forward to working with the FAA in meeting and exceeding these 

goals in the near future. · 

II. Additional Information 

Unmanned Aircraft System 

Name: Phantom 2 Vision Plus 

Manufacturer: DJI 

Model: S1000+ 

Weight: Max 5lb 

Battery Flight Time: 25 min 

Video Transmitter: DJI Vision 

Camera: DJI F /2.8 140° FOV 

Registered N Number: N577YG 
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Pre-flight Inspection, Maintenance 

123 West Front Street 

Traverse City, Michigan 49684 

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Before each flight the PIC will perform a series of pre-flight and takeoff checks as 

defined by the POH supplied. After each 60 minutes of airtime, the craft will undergo 

a thorough inspection of all aircraft components, including, but not limited to: 

a. Actuators I Servos 

b. Motors, wiring and connectors 

c. Propellers, smooth, no chips 

d. Electronic speed controller, wiring and connectors e. batteries, wiring and 

connectors 

f. Remote command and control 

g. Ground control station 

UAS Operating Parameters 

The petitioner states that all flights will be operated within visual line of sight (VLOS) of 

pilot, in daytime VFR flight conditions and all operations will be conducted with the 

assistance of a second spotter/observer. Altitude is accurately measured by GPS. The 

petitioner further states that an operator will ensure that only consenting production 

personnel will be allowed within 100 feet of the UA operation, and UAS will be kept at least 

1 00' from any inhabited structure. Generally the petitioner's UAS will be operated in 

Construction Sites and unpopulated areas. 

Petitioner's UAS will remain clear and yield the right of way to all manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, and hangliders). Petitioner will not conduct UAS operations within 5 

nautical miles of the geographic center of a non-towered airport unless a letter of agreement 

with that airport's management is obtained and the operation is conducted in accordance 

with a Notice to Airmen ("NOTAM"). 

Pilot in Command (PIC) 

The pilot in command will be Gourdie Fraser's Surveyor in Training, Jeff Fouch. Mr. Fouch has 

a Bachelor of Survey Engineering from Ferris State University with additional certificates from 

Northwestern Michigan College focused on Piloting and Programming autopilot systems for 

Unmanned Aerial Vehicles (See exhibit A). The PIC intends to develop safe techniques and 

applications for obtaining usable information from construction sites, utility inspections, and 

aerial photographs. UAV operations will be conducted in a safe and professional manner with 

a heavy emphasis on public and personnel safety. 

Regarding Petitioner's requested relief from 14 C.F.R. § 91.103(b)(1 ), Petitioner will comply 

with the other applicable procedures and requirements stated in § 91.1 03(a) and (b). 

Specifically, the PIC will take all actions including reviewing weather, flight battery 

requirements, aircraft performance data, and landing and takeoff distances before initiation 

of a flight. The PIC will also account for all relevant site-specific conditions in their preflight 
m Engineering 

Surveying 

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123 West Front Street 

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231 946 5874 Ill 

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procedures. Risks presented by sun glare will be mitigated by the PIC's and VO's ability to see 

other air traffic and initiate a return-to-home sequence if needed. 

Radio Frequencies 

Radio frequencies used will be those allotted by the FCC for data transmission and vehicle 

control in unlicensed frequency bands. All devices used will comply with FCC usage and 

emissions regulations. 

Safety and Benefits of the UAS 

The petitioner will be using the UAS in a variety of applications that generally require 

expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer 

many benefits over the use of full-sized manned aircraft for construction and surveying, 

electric power line inspection, oil/ gas pipeline inspection, advanced agriculture, film and still 

photography, just to name a few. GFA has close ties with state-wide utility companies and 

Department of Transportation operations and adding the use of a UAV would allow for safer 

working conditions and less time in hazardous working conditions. 

The Petitioner has supplied the following additional information: 

Appendix 

DJI Phantom 2 Vision Plus User Manual 

Conclusion 

For the foregoing reasons, the exemptions requested herein are essential for the performance 

of this specific technical services and procedures and the Petitioner should be permitted to 

conduct small UAS operations in accordance with its manuals and all other operating 

parameters deemed necessary and appropriate by the FAA. 
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Exhibit A 

PIC (Jeff Fouch)'s Certifications 

123 West Front Street 

Traverse City, Michigan 49684 

231 946.5874 a 

231 946 3703 Gil 

from Northwestern Michigan College's Unmanned Aviation Program 
Certificate of Completion 

Northwestern Michigan College 

UAS Program 

This certificate is awarded to 

Jeffery Fouch 

In recognition of the successful completion of 

the Aeryon Scout UAV Basic Training Course 

Tony Souerbrey 

UAS Progrom Monoger 

NMC 
Certificate of Completion 

Northwestern Michigan College 

UAS Program 

This certificate is awarded to 

Jeffery Fouch 

In recognition of the successful completion of 

the Draganfly X6 Multirotor Training Course 

---;;:-A_ 

Tony- Cuerbrey T 

UAS Program Manager 

-~ 

-----,--------------, -- --- ---- ---- --------

NMC 
Certificate of Completion 

Northwestern Michigan College 

UAS Program 

This certificate is awarded to 

Jeff Fouch 

In recognition of the successful completion of 

the MicroPilot autopilot training comse. 

Tony 

UAS Program 

'Sauerbrey 

Manager 

~ NMC 
Certificate of Completion 

Northwestern Michigan College 

UAS Program 

This certificate is awarded to 

Jeff Fouch 

In recognition of the successful completion of 

the Penguin B UAV Training Course with the 

Cloud Cap Pic autopilot system. 

~ .//, 

Ton 

a 

Sauerbrey 

~ 

UAS Program Manager 

NMC