## April 16, 2015

Exemption No. 11342 Regulatory Docket No. FAA

−20 15

−0039

Mr. Stavros Georgeadis Geosky3, LLC 1129 Vintner Boulevard Palm Beach Gardens, FL 33410
Dear Mr. Georgeadis : This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.
The Basis for Our Decision By letter dated January 7, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Geosky3, LLC (hereinafter petitioner or operator) for an exemption

. The exemption would all ow the petitioner to operate an unmanned aircraft system (UAS) to conduct security services, real estate photography and Geographic Information Systems for business and personal

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. Airworthiness Certification
The UAS proposed by the petitioner is a DJI Inspire 1 Model T600

.

## 2 The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates . In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA find s that the requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab a , Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213 ;
• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you pre sent; and

• A grant of exemption is in the public interest.
Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Geosky3, LLC is granted an exemption from 14 CFR §§ 61.23(a) and (c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.
Conditions and Limitations
In this grant of exemption, Geosky3, LLC is hereafter referred to as the operator.

## 3
Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.
1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 Model T600 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.
3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.
5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.
6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be u sed to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.
7. This exemption and all documents needed to operate the UAS and conduct its operation s in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the

## 4 operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.
8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.
9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.
10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been p erformed and the UAS is found to be in a condition for safe flight.
11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.
12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.
13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia , Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

## 5 qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.
15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorologic al conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.
16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.
17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property.
19. The PIC must abort the flight in the event of unpredi cted obstacles or emergencies.
20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.
21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

## 6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
24. The UA must remain clear and give way to all manned aviation operations and activities at all times.
25. The UAS may not be operated by the PIC from any moving device or vehicle.
26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under s uch protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. 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. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.
27. All operations shall be conducted over private or controlled

- access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.
28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area a s defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.
29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

## 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Offi ce (FSDO) with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N

- Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.
31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. This exemption terminates on April, 30, 2017 , unless sooner superseded or rescinded.
Sincerel y,

/s/ John S. Duncan Director, Flight Standards Service

# GEO SKY 3

January 7 , 2015
U.S. Dept. ofTransportation , Docket Operations West Building Ground Floor, Room wl2 -140 1200 New Jersey Avenue , SE. VIA FEDERAL EXPRESS 

### Pa lm 13c<:lch Gsrdcns

. Rorids

Washington , DC 20590 VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM



### Reference: Geosky3 Petition for Section 333 Exemption: Re: Small Unmanned Aircraft Systems in sec urity of aerial photograph y and geographic information system operations.
Dear Sir or Madam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. Part I I , Geosky3 , LLC Which is owned and operated by Mr. Stav r os Georgeadis (Pi lot Certificate 28 16315) is petitioning for an exempt ion from the Federa l Aviation Regulations ( " FARs " ) and other rules/ statutes pertaining to the following described unmanned aircraft system (UAS) called in this app licati on the Q I System. Sect ion 333 ofth e FMRA addresses spec ia l rules for certain UAS and grants the FAA authority to allow fo r the safe ope rat ion of certa in (UAS) within th e national airspace. Geosky3 respectfully requests the FAA to exempt Geosky3 from these certa in regu lations to perform its services commercially and provide a positive imp act for the publ ic. Geosky3 provides security services , real estate photography and Geographic Information Systems (GIS) for business and personal. With the integration of umnanned aircraft technology into Geosky3 's services this
new avenue of intell ige n ce wi ll , in a positive way, im pact the publics with l ess of an environmental impact from manned a ir craft w ith their emiss ions and the fatal inju ries that they represent.
M r
. Stavros Georgead i s, the owner and operator ofGeosky3 , LLC , has been a part of the United States Government, wh ich , for the most part , inc lu ded dro n e technology for the past 12 years. Mr. Georgeadis holds a pi lots certificate with an IFR rating. He understands the regulations of ope rating a mann ed aircraft and the potent ial of unmanned aircraft technology that ca n be used in a safe manne r under the FAA ' s approval. Geosky3 has the operational maturity to deploy safe l y and provide the benefits of UAS technology. Following the traditional standards of manned flights a standar d operating procedure (SOP) has been established which in cludes a pre-flight checkl i st , a flight checkl i st , a before landing checklist 1

, 

### and a area of interest (AO I) w ith dedicated waypoints. The pilot in command (P IC) will have complete control of flight. Flights would be conducted over the AOI by permission and altitudes will not exceed 400' AGL. A ground
crew of3 will cons i st of a PIC , a Visual Observer (VO) for line of sight and a Communications Officer (CO) who will be maintaining FAA ai r space communications as needed.
The Ql System (Inspire I Model T600) 1 

### that Geosky3 intends to deploy is manufactured by DJI Inn ovations , In c. DJ I supp l ies more than 50% of globa l demand fo r such veh i c l

es to comme rc ial and ind ustr i a l secto rs
. T h e compone nts are of mi litary-grade technology that is ava il able to the public. The Q I

1 Please sec graphic on page l 1

1System is a quad cop t er with carbon-fiber arms that can maintain stable and steady night within 22 knots of wind. The Ql has a G PS built in as well as an optical flow camera that maintains a s t ereoscopic image of the ground, which helps to prevent it from drilling if GPS is lost. Max flight time is 18-22 minutes but all Geosky3 operations are limited to 15 minutes (68-82% battery co nsumption) w ith a r eserve of 3-8 minute s ( 18-32% ba tt ery re serve) for return to b ase proc ed ures. A " dynamic h ome" b utt on on the remo te co n trol gives the P I C a o ne-t o uch button retu rn home / base action. The Q I System is con trolled by a remote contr o l base station and a Apple iPad wh ich runs an application (App) that provides airspeed. waypoints, compass , battery l ife, flight time and airspace inforn1ation.
The Q I Sys te m w i ll be operated in th e field in accordance with FAA Policy N 8900.227 Sec t ion 14 "Operational Re quirement s for UAS" and with the followin g Restr ictions: ( a) All flights will be restricted to I Olbs gross weight: (b) All opera ti ons will occur in FAA Class G airspace and not to exceed 40011 AG L , at an ai rspeed of no more than 25 knots and no further than 3/4 NM from the PIC or line of sig ht ; (c) Al l operations wi ll utilize a Pilot in Co mm and (P IC), V i sua l Observer (VO) and a Communications Officer (CO) at all times durin g a flight operation; (d) Operations will be restricted to flight s over private property with the permission of the property owner and any othe r perm iss ion needed for the area of operation; (c) Th e PIC must have accumulated and logged, in a m an n er cons i s ten t with 14 CFR 

### § 61.5 1 (b), a minimum of I 00 flight cyc l es and 25 hours of t otal t ime as a UAS ro to r c rafi pilot and at least ten h ours logged as a UAS pilot with a simi lar UAS type ; (f) All required permits will be obtained from state and local government pri or to operation; (g) The Q I System will not be operated over densely populated areas: (h) Th e Q I System will not be operated at ai r shows; (i) The Q I Sys tem will not be o p erated over any o p en-air assembly of people; 

### (j) T he Q I System wi ll not be operated over heavil y trafficked roads; (k) The 

### Q I System will not be operated within 5 NM of an airport or heliport; (I) Operations will be re s tricted to day only and wea th er conditions equivale nt to VFR: (m) The PI C w i ll brief the VO, CO and property owner about the operation and ri sk before the first flight at each new l ocation; ( n) No fli g ht may be made without a Pre-Fl igh t In spect ion by th e PIC before eac h operation to ascertain that the 

### Q I system i s in a cond iti on safe lor flight.
We s ubmit that the comb in ation of the UAS's light weight , flight performance and abi l ity , fully qualified flight crew and st rict operation under th e gu id elines established in 8900.227, and under all of the Res trictions (a) through (o) li s ted above , th e FAA can have fu ll confi d ence that the ope ra ti on wil l have an eq uivalent or greater leve l of sa f e ty than mann ed aircraft performing the same mission.
Name and address of the Petitioner:
Geos ky3 , LLC c/o Stavros Georgeadis 11 29 Vintner Blvd. Palm B each Gardens , FL 3341 0
Ph one : 561-337-5692 E m ai l : stav@Geosky3.com
1 4 CF R 11.81 (b)- Exemptions R equested:
The FAA considers unmanned aircraft as "a ircraft" flown by a " pilot" reg ardless ofthe locat ion of the p ilo t. All aircrall and pilot s mu s t com pl y wi th app l icab le sec tio n s of Tit le 14 of the Code of Fede r a l Regu lations ( 14 CF R) and oth er rules/regu lations to operate within the National Airspace. Unmanned aircraft are unable to comply with certain sections of 14 CFR as the regulations were written prior to the consideration of small UAS integration within the national ai r space. Th erefore Geosky3, LL C is



### 2

### re spec tfully requesting an exemption from cer tain parts of 1 4 CFR c ited be l ow, in add it ion to such further
exe mptions and rel i ef as the FAA may determine i s necessary to permit th e ope rations d esc ribed herein.
14 CFR Part 21 Subpart H

- Airworthiness cert i fication 14 CFR Part 45.23 & 

### 45.29- Display of marks; ge n era l & 

### S ize of Marks 14 CFR Part 61. 1 13 (a) and (b)

- Private pilot p ri v i leges and limit ations: Pilot in command 14 CFR Part 91. 109

- Flight Instruction 14 CFR Part 9 1 .119

- Minimum safe altitudes 14 CFR Part 9 1. 12 1

- Alt im ete r settings 14 CFR Part 9 1. 15 1

- Fuel req uir ements for flight in VFR conditions 14 CFR Part 9 1. 203 (a) and (b)

- C ivil Aircraft; Ce rtifi cat i ons Requ ired 14 CFR Part 9 1 .405

- Ma in tenance requ ir ed 1 4 CF R Part 9 1 .407

- Operation after maintenance , preventive maintenance , r ebuilding o r altera ti on 14 CFR Part 9 1.40 9

- In s pections 14 CFR Part 91.4 17

- Maintenance Records U

. S. DOT-FAA-Air Traffic Organization Polic y 14 CFR P art 91.7

- Civil Aircraft A ir worth iness 1 4 CF R Part 91

. 9 (b)

- C iv i I a ir c raft flight manual , marking and placard require ments Notic e N J O 7210 .87 3 (6. d ) FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)( I)

. . .Addendum Page 4
14 CF R Part 11.81 (c)

- The extent of reli ef Geosky3 seeks, and t he reason Geosky3 seeks the relief: Geosky3 , LLC seeks relief pursuant to this exemptio n !Tom app li cable part s of th e Federa l Aviat io n Regulations and oth er rule s/ regulations to th e e xtent n ecessary to permit c iv il flight operations within the nationa l airspace. Geosky3 , LLC seeks author ization to conduct small UAS flight operations within the perimeters of thi s exe mption request.
14 CFR Part 2 1 S ubpart H (Airw orthiness Cert ificate s).
Th is part establishes the procedures fo r th e issuance of an airworthiness certificate

. Wh i le th e FAA continues to work to deve l op airwo rt hiness standards fo r Unmanned Ae ri al Systems , we re qu est an experimental certificate be issued for the 

### Q I System under eithe r or both of th e follow in g provi sio ns: 2 1. 191 Expe rimenta l cert ificates. Expe r ime ntal cert ifi cates a r e i ssued for the following purpos es: (a) Research and development

. Testin g new aircraft d esig n concepts , new a ircraft equ ipm en t , new a ir craft installations, n ew aircraft operat ing techniques , o r new uses for aircraft. (b) Showing compliance with
r egu l ations, conduct ing flight tests and other operat ions to show com pliance with th e airworthiness regulations includin g flights to show compliance for issuance of type and supp le m e nt a l type certificates , flights t o substantiate major design changes , and flights to show compl iance w ith the funct i on and
re li ab ilit y req uire m e nt s of th e regu lations. S ince th e experimental ce rt ificate can b e used for commerc ia l purp oses such as market su rveys , sa les demon s tration s, and customer crew training , we wou ld expect that
an ex p e rim e ntal certificate wou ld permi t our commercia l purpose as we ll. The a ircraft w ill n o t carry pe r sons or p r operty , will not carry fue l , and w ill on l y fly und e r s trict operationa l re quirem e nts. Comb in ed with the VAS's lightweight, being constructed primaril y of carb on fiber and plastic , we propose that the UAS will be a t leas t as safe, if not safer, than a conventionally certificat ed aircraft performing the same mission. If an experimenta l airworth iness certificate is n ot app r opriate for this applica ti on , th e n we re quest an exem ption of 14 CFR Part 2 1 , Subpart H , and th e req u ir eme nt for an a irworth iness certificate in general , citing the equiva l e nt level of safety out lin ed in th e p r ev ious p arag raph

. 14 CFR 45.23 (b) Display of mark s; ge n e ral and 45.29 Size of marks. Geosky3 , as the petitioner seeks r elief from Part 45

. 23 (b) re quirin g markings on certain sections of the a ir

craft and markings of a certain s iz e
. Additionally , the aircraft must d i splay the wo r d "EXPERIMENTAL" in letters at least 2 inch es high near th e e ntrance to the cab in , cockp it , or pilot station.



### 3The UAS does n o t have an entrance in which the word "EX P E RIM ENTAL" can be placed. Gcosky3 has reg istered their UAS in compliance \vith 14 CF R Pa rt 47 and h ave ob tained 

### N801SG as th e ir r egis tration
a nd will place th at N # r eg i s tra t io n o n th e UAS as large a s p rac ti cab le due to the UAS sma ll s izc 2 • W e prop ose to ach ieve an equivalent level of safety by includin g the word "EXPER IM ENTAL" in the placard
on th e side of the aircrafe where it will b e visib l e to all in th e vicinity of the airc ra ft while it is preparing for laun ch

. Finally , we w i ll di s play a t th e g ro und s tatio n a high contra st flag or banner that contains th e words "Unmanned Aircraft Ground S tati o n" in le tt ers 3 inches hi g h o r g r ea te r. Si nce the a ircraft wi ll operate with in 3/4 NM of the ground s t ation, the banner sho uld be vis ib le to anyone that observes the aircraft and chooses t o invest igate its point of o rigin

. 14 CFR 6 1.113 Pri vate pilot privileges and limitation s: Pilot in C ommand and 61.133 Commercial pilot privi l eges and limitation s.
Pa rt 61.113 (a) states that no person who holds a private pilot certificate may act as pilot in comman d of an a ir c raft that is carrying passengers o r p ropert y for compensa t io n o r hire; nor may th a t person , for compensa t io n o r hir e, act as pi lot in co mm and or an a ir cra ft Part 6 1.11 3 ( b ) states that a p r ivate pilo t m ay, for compensation or hire , act as pilot in command of an ai r craft in connection with any business o r employment if: (I) The flight i s only inc i den t al to that business or employ ment ; and (2) T he ai r cra ft does not carry passengers or property for compensat io n or hire. The FAA s tated that it had to d ete rmi ne th e level of pi lo t certificate a ppro pri a te for that proposed opera ti o n w ithin th e Grant of Exem pti on Regulatory Dock et No. FAA-20 14-0352

. The FAA said within the Grant that it cons iders the overridin g safety factor to be the airmanship s kill s acquired through UAS-s p ec ifi c flight cycles. flight time , and specific make and model expe rience and UAS testing.
Geo s ky3 agrees w ith this determination and our p roposed opera t ions requi r e that th e PIC mu s t e ither h old a Private Pilot Certificat e i ssued by the F AA or have logged 25 hours of flight experience in thi s type of UAS (QI Syste m ). Since there are currently no means available for the pilot of a UAS to gain th e expe rience in a n equ ivalent category a n d c l ass in o rd e r to app l y for a comme r cial pilot's l ice n se, Geos k y3 proposes to ge n e ra t e an eq ui va le nt leve l of sa fety by requiring ou r pilot s to complete, a t a minimum. FAA private pilot g r ound instructio n and pass the FAA Privat e Pilot written exam ination in addition t o com p let ing the pri vate pilot requirements. Since the airc raft cannot carry pas sengers or property, we f ee l we meet the intent of 61

. 1 13 Subparagrap h (b) even th o ugh th e inten t of th is appl ica ti on is to conduct a bus in ess.
14 CFR 91.109 Fli g ht I nstruction; Simu l ated in s trument ni ght and certa in fli g h t tests.
The regulation states, " No person may operate a civil a i rcraft that is be in g used for fli ght instruct ion unl ess th at aircraft ha s fully fun c ti o n ing dual control s ."
The Q-1 Systems· gro und-based cont rol station cons ists of a sma ll hand-held r adio transmitter and a second hand-he l d ground-based station can be added to control the Ql System for training**purpose s~.**  Both the stu d e nt and instructor ca n ope r ate the duel set of con trols sim ultan eo u sly. With both st ud en t and in stru c tor having "hands-on" th e contr ols during flight , we feel that thi s technique meets the int en t of91. 1 09 and provides an equivale nt level of sa f ety.
14 CFR 91.1 19 Minimum sa fe alt itude s: Ge neral.
The regulation states that over spar se l y populated areas the a ircraft cannot be opera t ed closer than 500 feet to an y person, vessel, ve h icle, o r s tructure.
S in ce ou r Q I System is r es tra int to 40 0 feet AGL G eosky3 would no t b e a bl e t o comp l y w it h thi s requirement. I n order to provid e an eq ui valent level of safety we will on ly fly over private property w ith in the size of the property and with th e permission of the owner o f the p roperty. The aircraft will n ot be

2 P l ease sec g rap hi c on page 12 3 Please sec graphic on page 1 2**~Please** sec graphic on page 1 3

4

### operate d ove r conges t e d areas o r over any open-air assembl y of p e rsons. The property owner will be briefed on the expec t ed r oute o f ni g ht and the assoc iat ed ri s k s to persons and property on th e ground

. The ai r craft will be o perated at a lo w a ltitud e a ll owing, if a power unit fails, an emergency landing wi th ou t undue hazard t o persons or pr ope rty on th e s urface. Therefo r e we maintain that due to the s ma ll s ize of the U/\S, the hazard to persons , vehicles and s tru c tur es i s m inimal compared to mann e d airc raft, which should be considered in g ranting th e exe mption.


### 14 CFR Pa rt 9 1.1 2 1 ( Altim eter Sett in gs).
This regulation sta tes that: (a) Eac h pe r son operating an airc raft s h a ll ma inta in the cru isi n g altitude o r flight leve l of that airc raft , as th e case may be , b y re f e rence to an a ltimet er that i s se t. when op e ratin g
- ( I ) B e low 18,000 feet MSL , to-(i) Th e cu rrent report e d a ltim ete r setting o f a station al ong th e r oute and w ith in I 00 naut ical m iles of the aircraft ; ( i i) l fthere is no s t at io n within th e area pre sc rib e d in paragraph (a)( l )(i) o f thi s se ction , the c urrent r eported altimeter setting of a n approp riate avai lable s ta tion; o r ( iii ) In th e case of
an aircraft n o t e quipp e d with a radio, the elevation of th e departure ai r port or an appropriat e altimete r se tting ava il ab le before departur e; or (2) At or above 18 , 000 feet MS L , to 29. 92" H g
. (b) T h e lowes t u sab le fli g ht lev e l i s determined by th e atmospheric press ure in th e area of o p erat ion as sho wn in the fo llowin g table:
C urrent a ltim e ter se tting Lowes t u sab l e flight lev e l
29.92 (or h ig h er) 180

2 9.91 th r ough 29.42 1 85
2 9.4 1 th rough 2 8.92 190

28.9 1 throug h 28 .4 2 19 5
2 8.41 through 2 7.92 200
27.9 1 throu g h 27.42 205

27 .4 1 th r o ug h 26. 92 210

(c) To convert m in imum alti tude prescrib ed unde r §§9 1.1 19 and 9 1. 177 to the minimum ni g ht leve l , th e pil o t shall t ake the flight l evel eq ui vale nt of the minimum altitude in feet and a dd the ap pro priate number o f f eet s pecified below, accordin g to the current r e port e d a ltim e t er se tt in g:

C urre nt alt im e ter se tting . I 

### A dju s tm e nt f actor
29.9 2 (or h i gher) None
29.91 thro u g h 29.42 500
2 9.41 thro u gh 2 8.92 1 ,000

2 8 .9 1 through 2 8.42 1 , 500



### 5

# .. . .

28.41 th r ough 27.92 2 , 000

27.9 1 throu g h 27.42 2 ,500

2 7.4 1 through 26.92 3,000

Although Geosky3 w ill not hav e a typical airc raft barom e tri c altime te r onboard the UAS. our intention is to ope rate w it hin VLOS and at or below 400 feet AGL. T hi s, in co mbinatio n w ith our UAS ' s capacity w i ll provide altitud e information t o b o th the P IC a nd mission Vi s ibl e Observer ( VO ) via a tel e m e tri c data f ee d which downl inks from the UAS to a ground ba sed controll e r. Pri o r t o each fli g ht the UA S PI C a nd m ission VO will confirm a ltitud e accu racy pri o r to launch.


### 14 CF R 9 1.1 5 1 F u e l r eq uir e m e nt s for fli g ht in V FR co nd iti o n s
. The r eg ulat io n provides th at no person may begin a flight in a n airp l ane under day-VFR condi ti ons unl ess there i s enough fuel t o fly to th e first point o f intended landing and to fly after that for at least 30 minutes.
We feel the in te nt i on of this paragrap h i s to provide an energy re se rve as a sa f e ty buffe r for de lays to landing. The UAS is batte r y operate d an d th e maxim u m du r ation of fl ig h t from a s ingle batt ery charge is a max flight tim e o f 18-22 minut es but all Geosky3 operations arc lim ited to 15 minutes (68 -8 2% battery
consu mpti o n ) with a reserve of 3 -8 minutes ( 1 8

- 32% b attery reserve) f o r return to base procedures. A

'' d y namic home " butt o n on th e rem o te control gives the P IC a o n e- touch button r e turn h ome/ base action. The 

### QI Syst e m i s controlled by a remot e co n tro l base station and a Apple iPad wh i ch r un s an app li cat ion (App) t hat prov ides ai rspeed , waypo in ts , compass, battery li f e, fl ight time and a irs p ace in fo r mat i on
. This will ensure th a t we meet th e reserve energy r equ ir e ment of thi s paragraph. W e r e quest an exemption to th e word " fu el" and as k for an equ iva lent int erp r eta ti on with th e word "energy".


### 14 C F R Pa r t 9 1. 203 (a) a nd ( b )

- 

### C i vi l Aircra f t ; Ce rtifi ca t io n s Req u i r e d

. Th ese r egulat io n s s tate th at (a) Exce p t as provid ed in §91. 7 1 5, no pe rson may o perate a civi I aircraft unle ss it has within it th e f o llowing: ( I) An appropriate and current airworthiness cert ificate. Each U. S. airworthiness certificate used t o com pl y wi th this s ubparag r a ph (except a special flight permit, a copy of the a pp licab l e operat i o ns s p ec ifi ca ti ons iss u ed under §2 1

. 197(c) o f thi s chapter, a ppropri ate sec tions of th e a ir carrier manual required by part s 12 1 and 135 of th i s chapt e r co ntaining that portion of th e operat ions s pec ifi ca t ion s i ss ued unde r §21. 197(c), o r an authorizat ion under §9 1 .6 11 ) mu s t have on it the reg i stration number a ss i gne d to the a ircraft u n d e r part 47 o f thi s chapter

. l l oweve r , the airw o rthiness cert ifi cate n ee d not have on it an assigned s p ecia l identification numb er bef o r e I 0 days after that number is fir s t affixed to the a ircraft

. A revised airworthiness c
. ertificate having on it an a ss igned speci al i den tificat ion number th at ha s b ee n affix e d t o an aircraft may o n l y be ob tain ed upon application to an FAA Flight Standards district office

. (2) An e ffect ive U

. S. reg i s tra tio n cert if ica te i ss u ed to its owner o r , for operation with in th e U nited States, the seco nd copy of th e Airc raft reg i s trati o n Appl icat io n as prov id e d f or in §4 7.31 (c) , o r a registration cer tifi catio n i ssued und er the laws of a foreign country. ( b) No person may operat e a c ivi l
a ircraft unles s th e airwo rthin ess certifica t e required by paragraph ( a ) of thi s sec ti o n o r a special fligh t au th o rizati o n iss ued under §9 1. 7 15 is displayed at the cabin or coc kpit entrance so that it is l egib le to passengers or c r ew.
S h o uld the FAA allow for th e exe mption of 14 CF R Part 2 1

. Geosky3 would n ot need an exempt ion from thi s r egu lati on. as an airworth i ness ce rtifi cate wou ld not be required; however s ince that exemption has not been rec e ived t o da te, Geosky3 seeks r e li ef from thi s r eg ulati o n. Geos ky 3 ha s s ubmitted for a r egistrati on and acquired N80 /SG, wh i c h wa s obtained thro u g h the FAA a nd w ill have the appropriate documentation availa bl e. It wi ll be co -l oca ted w ith the c r e w at th e g r o u nd contro l stat i on and available for in s pectio n upon request. In or d e r t o identify th e a ircraft, we propose that th e inf o rmation f o und o n the airw ort hin ess and registration cert ifi ca t es b e p e rm anent ly affi xed to the a ircra ll v ia placard conta inin g the fo ll o wing

6in fom1ation plus the word "EX P E R I MENTAL " t o sati s fy the requir e ment of 14 CFR 45

. 23 , which follows imm ed i a te l y after th e propo sed placard de sc r iption below:

EXPER I MENTAL Ma nu facturer:


### D./I lnn ovations, In c . 950 £Base lin e Ave

. S t e . 210 Apache Jun c tion AZ 8 5119 Model: Inspire I T600. Se rial Numb e r : W 1308L2-1020-1 7 0 

## If

fo und ple ase c o ntact: ( 91 7) 3-19-2222
14 CF R Su b part E (91.4 0 I

- 91.4 1 7 )

- Mainte n a n ce, Pr event ive M a int e n a n ce, Alte r atio n s.
Th e regulation pr ovides that th e o p erator is primari l y re s ponsible for maintaining the aircraft in an airworthy condition. inc lu ding comp liance with part 39 and 43. Paragraphs 91.407 and 91.409 require that th e aircraft b e "app rove d for r e turn to service by a person authorized und e r 43.7" afler maint e nance and inspec t io n
. It is our int en ti on that the PI C perform maintenance and in specti o n o f th e aircraft and "be aut ho ri zed to approve th e aircraft for return to service." The PIC will e n s ure that th e airc raft is in an airworthy condition prior to eve ry ni g ht and in additi o n conduct d e tailed in s p ec tions after every two h o urs of fli g ht. Maint enance perf orme d by the PIC i s limit ed t o r epair in g sma ll c ra ck s, r eplacing a propeller. checking electrical co nn ection s and updating softwar e and firmware for the on-b o ard compute r
. Th e manu f acturer or thei r de s ignated repair faci lity will perform a ll o ther maintenance. The PIC will document work performed in accordance with 91.417

. We f ee l that due t o the size, co n s truction , and simplic ity of the aircraft, the P I C
can e n sure an equivalent level of safety.

14 CFR Pa r t 9 1. 7 (Civ il A i rcraft Ainvorthiness).
This r eg ul at ion s tat es that (a) No person m ay ope rat e a c ivi l a ircraft unle ss it is in airworthy co ndition and (b) Th e p il ot in command o f a civil airc ra ft i s responsible for determining whether that a i rcrafl i s in
co ndit ion f o r safe fli g h t. Th e pilot in command sha ll d i s cont inu e the flight w h e n un-airworthy mechanical , electrical , o r s tru ct ural condition s occ ur. T hi s exe mpti on would n o t b e n ec e ssary sho uld th e FAA approve the exemption for 14 C FR Part 21 S ubpart H. If Geosky3 's UAS i s n o t requ i red to o bta in an airworth in ess certificate , th e n thi s woul d not apply ; however GeoSky3 would m a intain the UAS and the PIC would deem the UA S s afe fo r fli gh t operation s a n d discontinue any fli g h t if any mechanical , elect rica l , or s t mctural problem a rose.
1 4 C F R Part 91.9 ( b ) (C i v il A ir craft F li g h t Ma nu a l , n u 1rk in g a nd p laca r d r equireme nt s) and 14 CFR P art 9 1. 203 (a) a n d (b) (C i v il Ai r craft; Certi fi cat ion s Requ ir ed).
This r egu lat ion s tat es that no p erso n may o perate a U.S. registered c ivi l a ircraft-( I ) For wh i ch an Airplan e or Rotorcra ft Fli g ht Manual i s required b y P art 2 1.5 of 14 CF R unl ess there i s available in th e a ir c r aft a current , ap p roved Airplane or Rotorcraft F li ght Manual or th e manual provided f o r in 14 C FR P art 121.141 (b); an d (2) Fo r which an Airplane or Rotorcraft Flight Manual is not required by 14 CF R Part 21.5, un le ss th e r e i s available in th e aircraft a c urrent ap pr oved Airplane o r R otorcraft Fli g ht Manual , ap prove d manua l mat e rial , markin gs and placard s o r any combinat ion th ereof

. Based o n the FAA's Memorandum titl e d , " Int erpretat ion regarding wh ether certain required documents may be kept at an unmanned ai r craft ' s control s tation" , da t ed August 8. 2014, GeoSk y 3 feels th at reques ti ng relief from th ese regulatio n s may n ot be nece s sary. G eoSky3 will have in it s p os s e s sion, on site , th e UAS m a nufacture r ' s fligh t/opera ti o n s manual a n d regi s trati o n paperwor k.
8900

. 227 t > arag r aph 1 6(c)(4) PIC Med i cal and Para g raph 16(e)(l) O b s erver Medical.
This policy provides that both th e P IC a nd V O must h ave a val id FAA sec ond- c la ss med i ca l ce rtificate i ss u ed under p art 67 in order to perform as a pilot or ob s erve r.

7The UAS maximum gross weigh t is 6. 7 pounds , it i s cons tru c ted of carbon fiber and pla s ti c and th e PI C i s n ot on board. Both the PI C and the YO are required to be in YLOS. Given th e unlikely even t th at both the P IC and YO become medically incapacitated while the aircraft i s in night, th e UAS will return autonomously to the site of launching and land without crew intervention. Therefore, requi ring the P IC and YO to meet the same m edical requ irements as a commerc ial pilot carrying passengers in a large aircr aft is
an unnecessary burden. We propose that the minimum medical requirements for the PI C and YO be a FAA third c la ss medical certificate.
14 CFR Part 11.81 (d)

- The re : 1 so n s wh y granting GeoSky3's re q ue s t would be in the publi c intere s t ; that i s, ho w 

### it wo uld benefit the public as a whole:
Grantin g an exemption for Geosky3 would allow th e organ izati on to safely and efficiently conduc t small UAS night ope rations to assist its comm uniti es in providing security services, real estate photography and geographic information systems (GIS) for business or personal and in some emerge nc y cases assist with local first responders if ap pr oved.
UAS operations w i ll provide more efficient serv ice to its cl ients and comm unity and could positive l y impact the security o f property and relief operations via shared resources with first responders.
Without this exemption, Geosky3 wou l d be restricted t o ground only inspections which would not hav e the benefits ofUAS efficiency in terms of both service and safe t y. Property inspec ti o n s at th ese a r eas ar e di ffi cult and at t imes dangero u s for emp loyees to navi ga te, espec ia ll y when debri s and dwelling integrity i s an issue. Geosky3 , with the integration of unmanned aircraft t echnology int o Gcosky3 ' s services. will have an immediate and positive impact by providing enhanced services and experience while provid ing safer and environmentally efficient serv ice by dismissing the use of manned helicopters and their emissions. Thi s n ew avenue of intelligenc e will, in a p os iti ve way, impact the publ ics' inte r es t with a comp l e te eva lu atio n of th e ir sec urity an d l ess of an env ir onmen ta l impact from manned aircraft, emissions and th e fatal injur ies they represent.
14 CFR Part 11.81 (e)

- The r easons why granting th e exemption would not adversely affect safety, or how the exempt ion woul d provide a level o f safety at least equal to that provided by the rule from w hich GeoSky3 seeks the exemption: GcoSky3 r equests that the exe mpt io n be gran ted w ith th e following lim itatio n s and operationa l condit i ons. Th ese l imitat io n s and conditions w ill provide an enhanced leve l of safe ty and w ill be th e g uidin g principl es when GeoSky3 i s conducting operations under this exemp tion:
A. The small unmanned airc raft 

### (Q 1-System) systems maximum takeoff weight will be less than I Olbs. Detailed spec ific ations are inc lu ded in the manual s
. GeoS ky3 is willing to have its autho r ization restr i cted be l ow the 

### 55 lb. threshold to the opera tin g weight of the unmanned
a irc r aft id ent ifi ed. All pilot in com mand ( PI C) and visual obse r ve rs (YO) will comp l e te FAA certifie d privat e p il ot g r ound school and will h ave tak e n and passed the FAA Private Pi lot Written Exam. This ensures that all PIC and YO have th e knowledge regarding the Federal Aviation Regulations, Airspace , and othe r p ertinent knowledge to conduct safe ope rati ons of small-u nm anned aircraft systems. A GeoSky3 employee with a FAA private pilot certific at e and GeoSky3 Safety Officer that has been train ed on UAS opera ti ons will oversee all training/opera ti ons and ensure a ll P IC and YO receive proper training and abide by a ll pertinent r eg u latio n s
. T hi s employee/FAA pr ivate pilot w ill m eet all the flight review
r eq uirements spec ifi ed in 14 CFR Part 6 1 .56 in an aircran in wh ich th e PI C i s rated on her / hi s flight certificate. All PIC and YO will be trained in detail to each of the unmanned aircraft system platform's operations. systems , emergency procedures and pass every level oft rainin g

s Please sec file "attachment

_ O 1 "



### 8admin i stered by a GeoSky3 employee. Training records will be kept at GeoSky3 for every PIC and YO and will be available for review. Every PIC and YO will obtain an FAA Class 3 medical cert ifi cate

. B. The UAS will not be operated directly over any person, except authorized and consenting personne l at the site or unless the UAS is at suffic ient alt itu de not to create a hazard to other people or property on the ground.
C

. All flight operations wi ll be operated at an altitude of no more than 400ft above the ground (AGL) within daylight YFR conditions and within visual line of sight (YLOS). The UAS will be operated within YLOS of the PIC at all times. The UAS wi ll remain c lear and y ield the right of way to all other manned operations and act ivities at all times. All operations will utilize at least one visual observer (YO) and the PIC and YO will be able to communicate verbally at all times. The UAS will not operate within 5 nm of any airport unless a letter of agreement with that airport's management is obtained and the operation is conducted in accordance w ith a NOTAM , as required by a COA. All flights will be communicated to FAA F li ght Service with posted NOTAMS prior to the flight(s).
D. All flight operations will be conducted within lin e of sight of the pilot in command and visua l observer(s). Maximum total flight time for each flight will be 18-22 minutes but all Geosky3 operations are limited to 15 minutes (68-82% battery consumption) w ith a reserve of3-8 minutes ( 18

- 32% battery reserve) for return to base procedures. A " dynamic horne" button on the remote contro l gives the PIC a one-touch button return horne / base action.
E. Flight operations and safety briefings will be conducted prior to all planned small unmanned
a ircraft system flights and will be mandatory for PIC and YO. Briefings wi ll include weather reviews , take off , landing and aircraft performance data for those real time conditions, and full pre- and post-flight in spections /checkl i sts and briefings for each specific unmanned a irc raft system , including the ground control station being operated and account for any discrepancies (i.e. inoperable components , items or equipment that are not covered in the relevant preflight inspection sections of the operations manual.) Before conduct in g any flight, the radio frequency spectrum used for the operat i on and control of the UAS w ill comp l y with the FCC
o r ot h er appropr iate government oversight agency requirements.

F

. Any UAS that has undergone maintenance or alterat ions that affects the UAS operation or flight characterist i cs must undergo a functional test flight in accordance with the manufacturer ' s recommendat i ons
. The PIC who conducts the test flight w ill make an entry in the UAS aircraft records of the flight. All maintenance and alterations wi ll be properly documented in the a ircraf1 records. GeoSky3 will follow the UAS manufacturer ' s a ircraf1/component, maintenance , overhaul, replacement , inspection and life limit requirements. All maintenance , preventive maintenance , alterations , status of
r eplacement/overhaul component parts, and the total time in service of the UAS will be recorded and documented. GeoSky3 will comply with all manufacturer safety bulletins.
G. In the event of a communication l ost link , the UAS wi ll return to a specific predetermined location and once the UAS is safely recovered , all flight operations wi ll cease until any communication/ data link issues are properly resolved. The UAS wi ll abort the flight in the event of unpredicted obstacles or emergenc i es in accordance with the operator ' s manua l.
H

. Regarding privacy concerns, GeoSky3 will coordinate all activities with incident command and any other public officia l s. I. Any incident , accident or flight operation that tr ansgresses the l ate ra l or vertical boundaries of the operational area as defined by the applicable COA w ill be reported to the FAA ' s UAS Integration Office (AFS

- 80) within 24hrs. Accidents w ill be reported to the National Transportat i on Safety Board (NTSB) per instructions contained on the NTSB Web site:

9

### www
. nt s b

. com
. GeoSky3 wi ll s u spen d all fli gh t o p e rat io ns unt i l the in c ide nt , acc i de nt , o r tra n sgressio n i s reviewed by AFS- 80 an d aut h o riza ti o n to res um e o p era ti o n s i s p rovi d e d

. 14 CF R Part 11.81 (Q 

### A s ummary the FAA can publi s h in the Federal Regi s tet·, s t a ting : (I) T he rule fr om which y ou seck th e exem p ti o n Petitioner: G eoSkv3 1 4 CFR and F AA r e g ulation s th a t G e oS kv 3 seeks an exempti o n :
14 CF R Pa rt 2 1 Subpart H 14 CF R Pa rt 45

. 23 (b) 1 4 CF R Part 6 1. 1 1 3 (a) and (b) 1 4 C FR Pa rt 91.7 14 CFR Part 9 1. 9 (b) 14 CF R Part 9 1. 1 09 14 CF R Part 9 1. 1 19 1 4 CFR Par t 9 1. 121 14 CFR Part 91. 1 51 1 4 CF R Part 91.2 0 3 (a) a n d (b) 14 CF R P art 91.405 1 4 CFR P a rt 91.407 14 CF R P art 91.409 14 CFR P art 91.4 1 7 U.S. DOT-FAA-A ir Traffic Orga ni zation Po li cy No tice N J O 7210. 87 3 (6. d ) ( 2 ) A bri e f d escri p tion of the nature o f the e xe m p ti o n yo u s e e k: GeoSky3 seeks r e li e f f r o m th e a p plicab l e p a rt s o f 14 C FR 2 1 , 45 , 61 , 91 an d U.S

. DO T- FAA

- Air Traffic Organ izati on P olicy N ot i ce N J O 7210.873 (6.d) as requeste d wi th i n thi s p etit ion to a ll ow GeoSky3 to safe l y and e ffi c ien tl y conduc t civ i l UAS fl igh t opera ti ons. T h i s w ill h ave an imme d ia t e and pos it ive im p ac t by prov idi n g en h anced se rv ices a n d experience w h ile prov id ing safer and e n vironmentally e ffi c ient serv ice by d ismissing the u se of manne d he l icop t e rs and the ir e m issions

. This new aven u e of inte lli gence wi ll , in a pos it ive way , imp ac t th e p ubl ics ' interest w ith a co mp lete eva lu at io n of their security a n d less of an e n viro nm e n ta l im pac t f rom man ned a ir craft, emiss io n s and th e fat al in j ur ies th ey re p rese nt
14 CF R Pa rt 11.81 ( g )

- An y additi o n a l information, v iews or argument s avaiht b le to suppor t G eo S kv 3's re q u es t :
This exe mpt io n wo ul d allow GeoS k y3 to prov ide sec urity services , real es ta t e p hotog ra ph y a n d Geog r ap hi c In forma tio n Systems (G I S) fo r business , pe r sona l and commun it ies as a w h o le. Ad d it iona l d evelo p ment and ope r at i ons wo ul d be ne fi t no t only GeoS ky3 an d it's co mm u niti es, but wou ld allow GeoSky3 to se rve as a p artne r with the FAA an d othe rs wit h in the UAS commu n ity to a d vance th i s new and e m e r g ing t echno logy in a safe and con t rolle d enviro nm ent. GeoSky3 h as d emo n s tra t ed the value of ou r r equest t o ut i lize o ur U AS tec hnology an d in prod u ct ive an d safe manner w ithi n the FAA g ui delines.
14 C FR P a rt 11.81 (h)

- Re q ue st to e xe rci s e th e p rivil eges of th e e xe m pti on ou ts ide the U nite d St ate s , the reas on w hv the p etitione r n e ed s to do so: GeoSky3 d ocs n ot sec k to exercise the p r iv il eges of thi s exem p tion , s h ou l d it b e granted , o uts i de of th e United States. O ur re q ues t is str ict ly to be g r anted autho rity fo r c iv il UAS o p erat io n s at locatio n s w it h in the
na tio n a l airspace sys t e m
. S in cerely ,

S tavros G

. Geo r gea d is Membe r GeoSky3 LL C



### 10

## EASY, SAFE FLIGHT

INSPIRE 1 Ont' But:on**Ta<~OII** 

# H

'

.**~** Dy nam i c Home Po i nt

11

### 12

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