FAA UAS Team:

Upon review of th is petition summary, some significant errors and misrepresentations were noted. The AeroLogix petition has been negatively an d incorrectly represented by this FAA summary. It incorrectly states several key points
and fails to include important background information about p revious FAA

- Approved

sUAS operations under Public

- use COA 2014

- CSA

- 35 that AeroLogix has performed

since 2014

. The FAA summary states:

"Description of Relief Sought: The petitioner is seeking relief to amend Exemption No. 11370 to operate up to 600 feet AGL, within 500 feet from all nonparticipating persons, vessels, vehicles, and structures except during take

- off and landing, or on private or controlled

- access property without permission from the property owner or authori zed representative."

FAA Summary of Petition

- [Summary Notice No. PE

– 2016

– 0037 }

The petitioner is seeking relief to amend Exemption No. 113 70 to operate up to 600 feet AG L

...

This statement is correct

.

".

. .within 500 feet from all nonparticipating persons, vessels, vehicles, and structures except during take

- off and landing."

This statement is INCORRECT. "WITHIN" 500 feet implies distances less than 500
feet. AeroLogix requested to operate at 600 feet AGL in order to comply with FAR 91.119c through vertical clearances GREATER THAN 500 FEET from non

participa nts. AeroLogix would only operate at less than 500 feet clearance during
take off and landing evolutions. The AeroLogix proposed amendment clearly stated:

Proposed Amendment to Condition and Limitation 26:

"Except during takeoff and landing evolutions, all GeoStar sU AS flight operations shall be

conducted with at least 500 feet vertical or horizontal clearance from all nonparticipating persons, vessels, vehicles, and structures unless:

a. The owner/controller of any vessels, vehicles or structures has granted permis sion for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard."

AeroLogix 333 Amendment Request"...or on private or controlled

- access property without permi ssion from the property owner or

authorized representative."

This statement is INCORRECT. AeroLogix did not seek to operate "ON" private or controlled access property without permission of the property owner or authorize d representative. This describes criminal trespass and a desire to operate f rom someone's property without their permission. This is completely WRONG. We sought to operate in compliance with FAR 91.119(c) in the same manner as conventional
aircraft and in the same manner that the FAA has previously granted to AeroLogix

in Public

- Use COA 2014

- CSA

- 35. FAA approved operations regulated by FAR Part 91 and AeroLogix's Public

- Use COA do not require property owner permission for overflight , provided operations comply with FAR 91.119(c) and other applicable

FARs. AeroLogix was c lear in its proposed amendment and also proposed to SEEK PROPERTY OWNER PERMISSION when any operation could not comply with FAR 91.119(c) through vertical clearances:

Proposed Amendment to Condition and Limitation 27:

27. All GeoStar sUAS operations sh all comply with § 91.119(c) by maintaining at least 500 feet vertical or horizontal clearance from any non

- participating person, vehicle, vessel or structure. Any operations that cannot comply with § 91.119(c) through vertical clearances shall:

(a) Be re stricted to private or controlled

- access property with permission from the property owner/controller or authorized representative. And;

(b) Permission from the property owner/controller or authorized representative will be obtained for each flight to be conducted.

AeroLogix 333 Amendment Request

The FAA summary of our request also failed to include important background information that supports our request:

- There is no reference to AeroLogix's continuing operations as an FAA

- approved sUAS operator conducting Public

- sector operations under COA 2014

- CSA

- 35 that permit FAR 91.119(c) compliant operations up to 600 feet AGL.

- There is no reference made to AeroLogix's accident

- free safety record in operations
since 2014 that were conducted in the IDENTICAL manner as is being requested in the petition.

- There is no reference made to AeroLogix's proposed Public

- sector operations that require the type of authorizations requested in our petition.Since April 2015, AeroLogix has sought to clarify these issues and obtain proper

authoriz ation through FAA processes. AeroLogix ha s delayed the launch of its commercial sUAS business for over a year and gone to great lengths to properly

research and articulate its requests. We ask for f air and timely con sideration of our
requests. P ublic comment is a requirement for these processes and information presented to the public should be complete and accurate. This summary of the AeroLogix petition is not. It is a gross misrepresentation of our petit ion and will

result in unfai rly negative public commentary. AeroLogix request s it be retracted immediately and replaced with an accurate representation of our requests.

Timothy J. Bri ggs

President, AeroLogix C o nsul ting Inc.