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 and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, WestLAND Group, Inc. (WestLAND) an operator of the GeoBlu Surveyor 

800 Unmanned Aircraft System (“UAS” or “GeoBlu”), seeks and exemption from the Federal 

Aviation Regulations (FAR’s) listed below and as discussed in Annex A. 

The regulations from which the exemption is requested 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 explains why exemptions pursuant to the proposal set 

forth in this letter are appropriate, provide an equal equivalent level of safety, and are in the public 

interest. 

The requested exemption would authorize WestLAND commercial operations using the GeoBlu for 

mapping and survey applications for oil pipelines and electrical towers as well as perform precision 

aerial surveys that consist of still photographs and video taken by onboard cameras. GeoBlu takes a 
series of high-quality, still digital images that are 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 mapping, 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 imagery at a fraction of the cost of surveys using 

conventional aircraft. These savings result in enhance efficiency and productivity for the active 

affected activities, as well as environmental benefits. 

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently 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 exemption would authorize commercial operations of 

aerial surveys using the GeoBlu, which at 1.7 pounds is small in size. The GeoBlu will be operated 

under controlled conditions at low altitude and airspace. 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 manufactures training program for the UAS. The 

airspace in which the UAS will operate will be disclosed to the FAA in advance. 

Westland Group respectfully submits that because the small, unmanned aerial vehicle the GeoBlu 

will be used in lieu of comparatively hazardous operations now conducted with fixed wing and 

rotary conventional aircraft. The FAA can have confidence that the operations will achieve at least 

an equivalent level or greater level of safety. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation's (the FAA administrator’s) responsibilities under section 333(c) of the Reform Act 

to "establish requirements for the safe operation of such aircraft systems in the national airspace 

system." 

The name and address of the applicant are: 

Rich Josenhans with a copy to: Blanca Hoffmeier 

Westland Group Inc. Westland Group Inc. 

11023 Eucalyptus Street 25020 Avenue Stanford #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.net 

 
APPLICABLE LEGAL STANDARDS UNDER SECTION 333 

Airworthiness of the GeoBlu 

A critical element of the exemption application involves 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 fight management software that allows the 

operator to plan safely and efficiently a mission in 3-D and then monitor it in real time. Using the 

implanted camera, protected by a Velcro envelope, the GeoBlu takes a collection of high definition 

still images and /or video that are used later to generate 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 operator can easily take-off and land on almost any 

surface. Its low impact energy in case of a controlled 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 internal 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 onboard 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 capability that allows the operator to take manual 

actions during the flight (Go to Home, Go Land, Hold and Resume the mission) and also suspend 

the automated operations and take the manual control 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 GeoBlu will be subject to the following 

mandatory conditions, which are based upon operating conditions set forth for operation of UAS by 

commercial entities pursuant to certifications of authorization, with additional restrictions: 

• Unmanned Aircraft will weigh less than 55 lbs, including payload 

• Visual Line of Sight (VLOS) only; the unmanned aircraft must remain within the VLOS of 

the operator or visual observer 
• At all times the small unmanned aircraft must remain 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 persons not directly involved in the 

operation 

• Daylight-only operations (official sunrise to official 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 avoid 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 allowed 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 than 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 requirement 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 FAA approved knowledge testing 

center 

o Be vetted by the Transportation Security Administration 

o Obtain an unmanned aircraft operator certificate with 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 ground based human enterprise to the aerial 

platform of the GeoBlu, WestLAND will have the ability 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 minutes instead of days on even the smallest of 

projects. As the project size increases, the savings to both WestLAND and the client will 

increase exponentially. Information collected by the GeoBlu will change the entire decision 

making process and work flow. Instead of days to collect and process the ground-based data 

WestLAND can collect GeoBlu preliminary data and begin to provide intelligent data to our clients 

at a near real-time rate of information exchange. Improving 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 nominal in comparison to that of a traditional 

manned aircraft. A major advantage of the low operational expenses is that WestLAND can 

provide these ariel acquisition services at a much lower cost to the customer while remaining 
competitive 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 can perform its mission effectively and efficiently and 

literally land at your feet. The data from the mission 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 disaster 

or emergency situation. 

Conclusion 

Authorizing WestLAND to contact surveying and mapping 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. Westland’s UAV would be used to conduct tower 

and pipeline inspections in the matter that provides 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 inspections require humans to hike dangerous 

terrain and cliffs to get closer to a pipeline to do visual inspections or use traditional very costly

manned aircraft inspections. 

 

Given that the GeoBlu is compact, and the restricted, controlled environment, within which 

WestLAND will operate, (remote areas where non-accessible pipelines and electrical towers are 

located), WestLAND falls squarely within the type of operations that the FAA intended be 

authorized pursuant to Section 333. WestLAND’s proposed operations are similar to the operations 

authorized under Section 333 Grants, including several nearly identical types of operations. 

Accordingly, WestLAND requests that FAA grant it an exemption without delay. 

 

Respectfully submitted, 

 

 Blanca Hoffmeier 

 WestLAND Group, inc 
ANNEX A: EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY 

SHOWING UNDER APPLICABLE RULES SUBJECT TO EXEMPTION. 

WestLAND Group, requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the GeoBlu. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates, 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 utilization, 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 equivalent 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 requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and 

populated areas of the UAS involved. Analysis of these different criteria demonstrates that the 

GeoBlu operated without an airworthiness certificate, 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): Display 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 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.” 

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 lettering will be impossible. The word 

“PROVISIONAL” will be placed on the forward fuselage 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 will exist for airworthiness of GeoBlu.

An equivalent level of safety will be achieved by insuring compliance with the GeoBlu manuals prior 

to each flight. 
14 C.F.R. § 91.9(b)(2): Civil aircraft flight manual, 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 the intent of this requirement is to ensure that 

flight manual information is available to the aircrew 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 available 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 Instruction. 

The regulation provides that “No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls.” 

Flight instruction will be accomplished through an elaborated training program, using the first 

simulation mode of the flight management software GeoBlu. T he equivalent level of safety 

during the training will be achieved by the manufacturer providing the training as outlined in 

Exhibit 2 and through the use of experienced and qualified 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 station along the route and within 100 

nautical mile of the aircraft;

If there is no station within the area prescribed in 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 radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure.”

To provide an equivalent level of safety, the GeoBlu 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 variations in altitude are detected through the 

barometer. Hence, barometric bias induced by environmental factors is rejected. 

14. C.F.R. § 91.151(a): Fuel Requirements for Flight 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 point of intended landing and to fly after that for at

least 30 minutes. 

Given the area of operation for the GeoBlu, WestLAND believes that an equivalent level of safety 

is already achieved with the specific procedure preventing the GeoBLu to accept a takeoff order 

as the battery level is below a given value. Moreover, 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 Aircraft Certification and Registration.

This regulation provides as follows: 

“No person may operate a civil aircraft unless it has 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 special 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 registration documents or to display them on the 

UAS. In addition, there is no pilot or passengers on board the aircraft. 

To obtain an equivalent level of safety and meet the intent of 91.203, GeoBlu proposes that 

documents deemed appropriate for this aircraft by the FAA will be co-located with the operator at 

the ground control station in the GeoBlu box and available for inspection upon request. 

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

Alterations. 

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 

require that the aircraft be “approved for return to service by a person authorized under 43.7” after 

maintenance and inspection. Section 91.409(a)(2) requires 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 accomplished 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 GeoBlu will be accomplished by the 

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

An equivalent level of safety will be achieved because the GeoBlu is small in size, it is not a 

complex mechanical device, it will carry no external 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 airworthy 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 part is running properly. If a problem is 

detected, the GeoBlu will not be able to be switched-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 GeoBlu are easily interchangeable (propellers), which 

allows the operator to make sure the propellers and propulsion systems are always airworthy when 

a mission is initiated.