FAA UAS Team:

Upon review of this petition summary, some significant errors and 

misrepresentations were noted. The AeroLogix petition has been negatively and 

incorrectly represented by this FAA summary. It incorrectly states several key points 

and fails to include important background information about previous 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 authorized representative."

FAA Summary of Petition - [Summary Notice No. PE–2016–0037}

The petitioner is seeking relief to amend Exemption No. 11370 to operate up to 600 feet AGL...

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 nonparticipants. AeroLogix would only operate at less than 500 feet clearance during 

takeoff and landing evolutions. The AeroLogix proposed amendment clearly stated:

Proposed Amendment to Condition and Limitation 26:

"Except during takeoff and landing evolutions, all GeoStar sUAS 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 permission 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 permission 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 authorized 

representative. This describes criminal trespass and a desire to operate from 

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 clear 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 shall 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 restricted 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 

authorization through FAA processes. AeroLogix has 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 fair and timely consideration of our 

requests. Public 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 petition and will 

result in unfairly negative public commentary. AeroLogix requests it be retracted 

immediately and replaced with an accurate representation of our requests.

Timothy J. Briggs

President, AeroLogix Consulting Inc.