April 16, 2015

 Exemption No. 11342

 Regulatory Docket No. FAA−2015−0039

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 allow 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 describing 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.
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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 finds 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 Laba, 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 present; 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.
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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 used 

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 

operations 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 
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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 performed 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 review 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 
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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 meteorological 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 FAApublished 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 predetermined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted 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 (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings must be 

as large as practicable.
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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 such 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 as 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.
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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 Office (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.

Sincerely,

/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 

Palm 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 

security of aerial photography 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. Stavros Georgeadis (Pilot Certificate 28 16315) is 

petitioning for an exemption from the Federal Aviation Regulations ("F ARs" ) and other rules/statutes 

pertaining to the following described unmanned aircraft system (UAS) called in this application the Q I 

System. Section 333 of the FMRA addresses special rules for certain UAS and grants the FAA authority to 

allow for the safe operation of certain (UAS) within the national airspace. Geosky3 respectfully requests 

the FAA to exempt Geosky3 from these certain regulations to perform its services commercially and 

provide a positive impact for the public. 

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 intelligence will, in a positive way, impact the publics with less of an environmental impact 

from manned aircraft with their emissions and the fatal injuries that they represent. 

Mr. Stavros Georgeadis, the owner and operator ofGeosky3, LLC, has been a part of the United States 

Government, which, for the most part, included drone technology for the past 12 years. Mr. Georgeadis 

holds a pilots certificate with an IFR rating. He understands the regulations of operating a manned aircraft 

and the potential of unmanned aircraft technology that can be used in a safe manner under the FAA's 

approval. 

Geosky3 has the operational maturity to deploy safely and provide the benefits of UAS technology. 

Following the traditional standards of manned flights a standard operating procedure (SOP) has been 

established which includes a pre-flight checklist, a flight checklist, a before landing checklist1

, and a area of 

interest (AOI) with dedicated waypoints. The pilot in command (PIC) 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 consist of a PIC, a Visual Observer (VO) for line of sight and a Communications Officer 

(CO) who will be maintaining FAA airspace communications as needed. 

The Ql System (Inspire I Model T600)1 that Geosky3 intends to deploy is manufactured by DJI 

Innovations, Inc. DJI supplies more than 50% of global demand for such veh ic les to commercial and 

industria l sectors. The components are of mi litary-grade technology that is available to the public. The Q I 

1 Please sec graphic on page l 1 

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System is a quad copter 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 stereoscopic 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 consumption) with a reserve of 3-8 minutes 

( 18-32% battery reserve) for return to base procedures. A "dynamic home" button on the remote control 

gives the PIC a one-touch button return home/base action. The Q I System is controlled by a remote 

control base station and a Apple iPad which runs an application (App) that provides airspeed. waypoints, 

compass, battery life, flight time and airspace inforn1ation. 

The Q I System will be operated in the field in accordance with FAA Policy N 8900.227 Section 14 

"Operational Requirements for UAS" and with the following Restrictions: 

(a) All flights will be restricted to I Olbs gross weight: 

(b) All operations will occur in FAA Class G airspace and not to exceed 40011 AGL, at an airspeed of 

no more than 25 knots and no further than 3/4 NM from the PIC or line of sight; 

(c) All operations will utilize a Pilot in Command (PIC), Visual Observer (VO) and a 

Communications Officer (CO) at all times during a flight operation; 

(d) Operations will be restricted to flights over private property with the permission of the property 

owner and any other perm iss ion needed for the area of operation; 

(c) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.5 1 (b), a 

minimum of I 00 flight cycles and 25 hours of total time as a UAS rotorcrafi pilot and at least ten 

hours logged as a UAS pilot with a similar UAS type; 

(f) All required permits will be obtained from state and local government prior to operation; 

(g) The Q I System will not be operated over densely populated areas: 

(h) The Q I System will not be operated at air shows; 

(i) The Q I System will not be operated over any open-air assembly of people; 

(j) The Q I System will not be operated over heavily trafficked roads; 

(k) The Q I System will not be operated within 5 NM of an airport or heliport; 

(I) Operations will be restricted to day only and weather conditions equivalent to VFR: 

(m) The PIC will brief the VO, CO and property owner about the operation and risk before the first 

flight at each new location; 

(n) No flight may be made without a Pre-Flight Inspection by the PIC before each operation to 

ascertain that the Q I system is in a condition safe lor flight. 

We submit that the combination of the UAS's light weight, flight performance and ability, fully qualified 

flight crew and strict operation under the guidelines established in 8900.227, and under all of the 

Restrictions (a) through (o) listed above, the FAA can have fu ll confidence that the operation will have an 

equivalent or greater level of safety than manned aircraft performing the same mission. 

Name and address of the Petitioner: 

Geosky3, LLC 

c/o Stavros Georgeadis 

11 29 Vintner Blvd. 

Palm Beach Gardens, FL 3341 0 

Phone: 561-337-5692 

Email: stav@Geosky3.com 

14 CFR 11.81 (b)- Exemptions Requested: 

The FAA considers unmanned aircraft as "aircraft" flown by a " pilot" regardless ofthe location ofthe 

pilot. All aircrall and pilots must comply with applicable sections of Title 14 of the Code of Federal 

Regulations ( 14 CFR) and other rules/regulations 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 airspace. Therefore Geosky3, LLC is 

2 
respectfully requesting an exemption from certain parts of 14 CFR cited below, in addit ion to such further 

exemptions and rel ief as the FAA may determine is necessary to permit the operations described herein. 

14 CFR Part 21 Subpart H - Airworthiness certification 

14 CFR Part 45.23 & 45.29- Display of marks; general & Size of Marks 

14 CFR Part 61. 113 (a) and (b) - Private pilot privileges and limitations: 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 - Altimeter settings 

14 CFR Part 9 1. 15 1 - Fuel requirements for flight in VFR conditions 

14 CFR Part 9 1.203 (a) and (b) - Civil Aircraft; Certifications Required 

14 CFR Part 9 1.405 - Maintenance required 

14 CFR Part 9 1.407 - Operation after maintenance, preventive maintenance, rebuilding or alteration 

14 CFR Part 9 1.409 - Inspections 

14 CFR Part 91.4 17 - Maintenance Records U.S. DOT-FAA-Air Traffic Organization Policy 

14 CFR Part 91.7 - Civil Aircraft Airworthiness 

14 CFR Part 91 .9 (b) - Civi I a ircraft flight manual, marking and placard requirements 

Notice N JO 7210.873 (6.d) 

FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)( I) ... Addendum Page 4 

14 CFR Part 11.81 (c) - The extent of relief Geosky3 seeks, and the reason Geosky3 seeks the relief: 

Geosky3, LLC seeks relief pursuant to this exemption !Tom applicable parts of the Federal Aviation 

Regulations and other rules/regulations to the extent necessary to permit civil flight operations within the 

national airspace. Geosky3, LLC seeks authorization to conduct small UAS flight operations within the 

perimeters of this exemption request. 

14 CFR Part 21 S ubpart H (Airworthiness Certificates). 

This part establishes the procedures for the issuance of an airworthiness certificate. Wh ile the FAA 

continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an 

experimental certificate be issued for the Q I System under either or both of the follow ing provisions: 

2 1. 191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) 

Research and development. Testing new aircraft design concepts, new a ircraft equipment, new aircraft 

installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with 

regulations, conducting flight tests and other operations to show compliance with the airworthiness 

regulations including flights to show compliance for issuance of type and supplemental type certificates, 

flights to substantiate major design changes, and flights to show compliance with the function and 

reliability requirements of the regulations. Since the experimental certificate can be used for commercial 

purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that 

an experimental certificate would permit our commercial purpose as well. The aircraft will not carry 

persons or property, will not carry fue l, and will only fly under strict operational requirements. Combined 

with the VAS's lightweight, being constructed primarily of carbon fiber and plastic, we propose that the 

UAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same 

mission. 

If an experimental airworthiness certificate is not appropriate for this application, then we request an 

exemption of 14 CFR Part 2 1, Subpart H, and the requirement for an airworthiness certificate in general, 

citing the equivalent level of safety outlined in the previous paragraph. 

14 CFR 45.23 (b) Display of marks; general and 45.29 Size of marks. 

Geosky3, as the petitioner seeks relief from Part 45.23 (b) requiring markings on certain sections of the 

aircraft and markings of a certain size. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. 

3 
The UAS does not have an entrance in which the word "EXPERIM ENTAL" can be placed. Gcosky3 has 

registered their UAS in compliance \vith 14 CFR Part 47 and have obtained N801SG as the ir registration 

and will place that N# registration on the UAS as large as practicable due to the UAS small sizc2

• We 

propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard 

on the side of the aircrafe where it will be visible to all in the vicinity of the aircra ft while it is preparing 

for launch. Finally, we will display at the g round station a high contrast flag or banner that contains the 

words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will 

operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the 

aircraft and chooses to investigate its point of origin. 

14 CFR 6 1.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial 

pilot privileges and limitations. 

Part 61.113 (a) states that no person who holds a private pilot certificate may act as pilot in command of an 

a ircraft that is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command or an aircraft Part 6 1.11 3 (b) states that a private pilot may, 

for compensation or hire, act as pilot in command of an aircraft in connection with any business or 

employment if: (I) The flight is only incidental to that business or employment; and (2) The aircraft does 

not carry passengers or property for compensation or hire. The FAA stated that it had to determine the 

level of pilot certificate appropriate for that proposed operation within the Grant of Exemption Regulatory 

Docket No. F AA-20 14-0352. The FAA said within the Grant that it considers the overriding safety factor 

to be the airmanship skills acquired through UAS-specific flight cycles. flight time, and specific make and 

model experience and UAS testing. 

Geosky3 agrees with this determination and our proposed operations require that the PIC must either hold a 

Private Pilot Certificate issued by the FAA or have logged 25 hours of flight experience in this type of UAS 

(QI System). Since there are currently no means available for the pilot of a UAS to gain the experience in 

an equivalent category and c lass in order to apply for a commercial pilot's license, Geosky3 proposes to 

generate an equivalent level of safety by requiring our pilots to complete, at a minimum. FAA private pilot 

ground instruction and pass the FAA Private Pilot written examination in addition to completing the private 

pilot requirements. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 

61 .113 Subparagraph (b) even though the intent of this application is to conduct a business. 

14 CFR 91.109 Flight Instruction; Simulated instrument night and certa in flight tests. 

The regulation states, "No person may operate a civil aircraft that is being used for flight instruction unless 

that aircraft has fully function ing dual controls." 

The Q-1 Systems· ground-based control station consists of a small hand-held radio transmitter and a second 

hand-held ground-based station can be added to control the Ql System for training purposes~. Both the 

student and instructor can operate the duel set of controls simultaneously. With both student and instructor 

having "hands-on" the controls during flight, we feel that this technique meets the intent of91. 1 09 and 

provides an equivalent level of safety. 

14 CFR 91.1 19 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet 

to any person, vessel, vehicle, or structure. 

Since our Q I System is restraint to 400 feet AGL Geosky3 would not be able to comply with this 

requirement. In order to provide an equivalent level of safety we will only fly over private property within 

the size of the property and with the permission of the owner of the property. The aircraft will not be 

2 Please sec graphic on page 12 3 Please sec graphic on page 12 

~Please sec graphic on page 13 

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operated over congested areas or over any open-air assembly of persons. The property owner will be 

briefed on the expected route of night and the associated risks to persons and property on the ground. The 

aircraft will be operated at a low a ltitude a llowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the 

U/\S, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should 

be considered in granting the exemption. 

14 CFR Part 9 1.121 (Altimeter Settings). 

This regulation states that: (a) Each person operating an aircraft shall maintain the cru ising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set. when operating- ( I) Below 

18,000 feet MSL, to-(i) The current reported a ltimeter setting of a station along the route and within I 00 

nautical miles ofthe aircraft; (ii) lfthere is no station within the area prescribed in paragraph (a)( l)(i) of 

this section, the current reported altimeter setting of an appropriate available station; or (iii) 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; or (2) At or above 18,000 feet MSL, to 29.92" Hg.(b) The lowest usable 

flight level is determined by the atmospheric pressure in the area of operation as shown in the fo llowing 

table: 

Current a ltimeter setting Lowest usable flight level 

29.92 (or higher) 180 

29.91 through 29.42 185 

29.4 1 through 28.92 190 

28.9 1 through 28.42 195 

28.41 through 27.92 200 

27.9 1 through 27.42 205 

27.4 1 through 26.92 210 

(c) To convert minimum altitude prescribed under §§9 1.1 19 and 9 1. 177 to the minimum night level, the 

pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of 

feet specified below, according to the current reported a ltimeter setting: 

Current altimeter setting .I 

Adjustment factor 

29.92 (or higher) None 

29.91 through 29.42 500 

29.41 through 28.92 1,000 

28.91 through 28.42 1,500 

5 
.... 

28.41 through 27.92 2,000 

27.9 1 through 27.42 2,500 

2 7.4 1 through 26.92 3,000 

Although Geosky3 will not have a typical aircraft barometric altimeter onboard the UAS. our intention is to 

operate within VLOS and at or below 400 feet AGL. This, in combination with our UAS's capacity will 

provide altitude information to both the PIC and mission Visible Observer (VO) via a telemetric data feed 

which downlinks from the UAS to a ground based controller. Prior to each flight the UAS PIC and mission 

VO will confirm a ltitude accuracy prior to launch. 

14 CFR 9 1.151 Fuel req uirements 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. 

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The UAS is battery operated and the maximum duration of fl ight from a single battery charge is a 

max flight time of 18-22 minutes but all Geosky3 operations arc limited to 15 minutes (68-82% battery 

consumption) with a reserve of 3-8 minutes ( 18-32% battery reserve) for return to base procedures. A 

''dynamic home" button on the remote control gives the PIC a one-touch button return home/base action. 

The Q I System is controlled by a remote control base station and a Apple iPad wh ich runs an application 

(App) that provides airspeed, waypoints, compass, battery life, fl ight time and a irspace information. This 

will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the 

word "fuel" and ask for an equivalent interpretation with the word "energy". 

14 CFR Pa rt 9 1.203 (a) and ( b) - Civil Aircraft; Certifications Required. 

These regulations state that (a) Except as provided in §91. 7 15, no person may operate a civi I aircraft unless 

it has within it the fo llowing: ( I) An appropriate and current airworthiness certificate. Each U.S. 

airworthiness certificate used to comply with this subparagraph (except a special flight permit, a copy of 

the applicable operations specifications issued under §2 1.197(c) of this chapter, appropriate sections of the 

air carrier manual required by parts 12 1 and 135 of this chapter containing that portion of the operations 

specifications issued under §21. 197(c), or an authorization under §9 1.6 11 ) must have on it the registration 

number assigned to the aircraft under part 47 o f this chapter. l lowever, the airworthiness certificate need 

not have on it an assigned special identification number before I 0 days after that number is first affixed to 

the a ircraft. A revised airworthiness c.ertificate having on it an assigned special identification number that 

has been affixed to an aircraft may only be obtained upon application to an FAA Flight Standards district 

office. (2) An effective U.S. registration certificate issued to its owner or, for operation within the United 

States, the second copy of the Aircraft registration Application as provided for in §47.31 (c), or a 

registration certification issued under the laws of a foreign country. (b) No person may operate a civil 

aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight 

authorization issued under §9 1. 7 15 is displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. 

Should the FAA allow for the exemption of 14 CFR Part 2 1. Geosky3 would not need an exemption from 

this regulation. as an airworthiness certificate would not be required; however since that exemption has not 

been received to date, Geosky3 seeks relief from this regulation. Geosky3 has submitted for a registration 

and acquired N80 /SG, which was obtained through the FAA and will have the appropriate documentation 

available. It will be co-located with the crew at the ground control station and available for inspection upon 

request. In order to identify the aircraft, we propose that the information found on the airworthiness and 

registration certificates be permanently affixed to the aircrall via placard containing the fo llowing 

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infom1ation plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23, which follows 

immed iate ly after the proposed placard description below: 

EXPERIMENTAL Manu facturer: 

D./I lnnovat ions, Inc. 

950 £Baseline Ave. Ste. 210 Apache Junction AZ 85119 Model: Inspire I T600. Serial Number: 

W 1308L2-1020-170 

If f ound please contact: (917) 3-19-2222 

14 CFR Sub part E (91.40 I - 91.4 17) - Maintena nce, Preventive Ma intena nce, Alterations. 

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

airworthy condition. including compliance with part 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" afler maintenance and 

inspection. 

It is our intention that the PIC perform maintenance and inspection o f the aircraft and "be authorized to 

approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition 

prior to every night and in addition conduct detailed inspections after every two hours of flight. 

Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller. checking 

electrical connections and updating software and firmware for the on-board computer. The manufacturer or 

their designated repair facility will perform all other maintenance. The PIC will document work performed 

in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC 

can ensure an equivalent level of safety. 

14 CFR Part 9 1.7 (Civil Aircraft Ainvorthiness). 

This regulation states that (a) No person may operate a civil aircraft unless it is in airworthy condition and 

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircrafl is in 

condit ion for safe flight. The pilot in command shall discontinue the flight when un-airworthy mechanical, 

electrical, or structural conditions occur. This exemption would not be necessary should the FAA approve 

the exemption for 14 CFR Part 21 Subpart H. If Geosky3 's UAS is not required to obtain an airworthiness 

certificate, then this would not apply; however GeoSky3 would maintain the UAS and the PIC would deem 

the UAS safe for flight operations and discontinue any flight if any mechanical, electrical, or stmctural 

problem arose. 

14 C FR Part 91.9 (b) (Civil Aircraft Flight Manua l, nu1rking a nd placar d requirements) and 14 CFR 

Part 9 1.203 (a) a nd (b) (Civil Air craft; Certifi cations Required). 

This regulat ion states that no person may operate a U.S. registered civil aircraft-( I) For wh ich an Airplane 

or Rotorcraft Flight Manual is required by Part 2 1.5 of 14 CFR unless there is available in the aircraft a 

current, approved Airplane or Rotorcraft Flight Manual or the manual provided for in 14 CFR Part 121.141 

(b); and (2) For which an Airplane or Rotorcraft Flight Manual is not required by 14 CFR Part 21.5, unless 

there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual 

material, markings and placards or any combination thereof. Based on the FAA's Memorandum titled, 

" Interpretation regarding whether certain required documents may be kept at an unmanned aircraft's 

control station", dated August 8. 2014, GeoSky3 feels that requesting relief from these regulations may not 

be necessary. GeoSky3 will have in its possession, on site, the UAS manufacturer's flight/operations 

manual and registration paperwork. 

8900.227 t>aragraph 16(c)(4) PIC Medical and Paragraph 16(e)(l) Observer Medical. 

This policy provides that both the PIC and VO must have a valid FAA second-c lass med ical certificate 

issued under part 67 in order to perform as a pilot or observer. 

7 
The UAS maximum gross weight is 6.7 pounds, it is constructed of carbon fiber and plastic and the PIC is 

not on board. Both the PIC and the YO are required to be in YLOS. Given the unlikely event that both the 

PIC and YO become medically incapacitated while the aircraft is in night, the UAS will return 

autonomously to the site of launching and land without crew intervention. Therefore, requiring the PIC and 

YO to meet the same medical requirements as a commercial pilot carrying passengers in a large aircraft is 

an unnecessary burden. We propose that the minimum medical requirements for the PIC and YO be a 

FAA third c lass medical certificate. 

14 CFR Part 11.81 (d) - The re:1sons why granting GeoSky3's req uest would be in the public 

interest; that is, how it would benefit the public as a whole: 

Granting an exemption for Geosky3 would allow the organization to safely and efficiently conduct small 

UAS night operations to assist its communities in providing security services, real estate photography and 

geographic information systems (GIS) for business or personal and in some emergency cases assist with 

local first responders if approved. 

UAS operations will provide more efficient service to its clients and community and could positively 

impact the security of property and relief operations via shared resources with first responders. 

Without this exemption, Geosky3 wou ld be restricted to ground only inspections which would not have the 

benefits ofUAS efficiency in terms of both service and safety. 

Property inspections at these areas are diffi cult and at times dangerous for employees to navigate, 

especially when debris and dwelling integrity is an issue. 

Geosky3, with the integration of unmanned aircraft technology into Gcosky3 's services. will have an 

immediate and positive impact by providing enhanced services and experience while providing safer and 

environmentally efficient service by dismissing the use of manned helicopters and their emissions. This 

new avenue of intelligence will, in a positive way, impact the publics' interest with a complete evaluation 

of their security and less of an environmenta l impact from manned aircraft, emissions and the fatal injuries 

they represent. 

14 CFR Part 11.81 (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 

GeoSky3 seeks the exemption: 

GcoSky3 requests that the exemption be granted with the following limitations and operational conditions. 

These limitations and conditions will provide an enhanced level of safety and will be the guiding principles 

when GeoSky3 is conducting operations under this exemption: 

A. The small unmanned aircraft (Q 1-System) systems maximum takeoff weight will be less than 

I Olbs. Detailed specifications are included in the manuals. GeoSky3 is willing to have its 

authorization restricted below the 55 lb. threshold to the operating weight of the unmanned 

aircraft identified. All pilot in command (PIC) and visual observers (YO) will complete FAA 

certified private pilot ground school and will have taken and passed the FAA Private Pilot 

Written Exam. This ensures that all PIC and YO have the knowledge regarding the Federal 

Aviation Regulations, Airspace, and other pertinent knowledge to conduct safe operations of 

small-unmanned aircraft systems. A GeoSky3 employee with a FAA private pilot certificate 

and GeoSky3 Safety Officer that has been trained on UAS operations will oversee all 

training/operations and ensure a ll PIC and YO receive proper training and abide by a ll 

pertinent regulations. This employee/FAA private pilot will meet all the flight review 

requirements specified in 14 CFR Part 6 1.56 in an aircran in which the PIC is rated on her/his 

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 oftraining 

s Please sec file "attachment_O 1" 

8 
admin istered 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 certificate. 

B. The UAS will not be operated directly over any person, except authorized and consenting 

personnel at the site or unless the UAS is at sufficient altitude not to create a hazard to other 

people or property on the ground. 

C. All flight operations will 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 will remain c lear and y ield the 

right of way to all other manned operations and activities 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 with a NOT AM, as required by a COA. All flights will be communicated to FAA 

Flight Service with posted NOT AMS prior to the flight(s). 

D. All flight operations will be conducted within line of sight of the pilot in command and visual 

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) with a reserve of3-8 

minutes ( 18-32% battery reserve) for return to base procedures. A " dynamic horne" button on 

the remote control 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 

aircraft system flights and will be mandatory for PIC and YO. Briefings will include weather 

reviews, take off, landing and aircraft performance data for those real time conditions, and full 

pre- and post-flight inspections/checklists and briefings for each specific unmanned aircraft 

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 conducting any flight, the radio 

frequency spectrum used for the operation and control of the UAS will comply with the FCC 

or other appropriate government oversight agency requirements. 

F. Any UAS that has undergone maintenance or alterations that affects the UAS operation or 

flight characteristics must undergo a functional test flight in accordance with the 

manufacturer's recommendations. The PIC who conducts the test flight will make an entry in 

the UAS aircraft records of the flight. All maintenance and alterations wi ll be properly 

documented in the aircraf1 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 

replacement/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 lost link, the UAS will 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 will abort the flight in the 

event of unpredicted obstacles or emergencies in accordance with the operator's manual. 

H. Regarding privacy concerns, GeoSky3 will coordinate all activities with incident command 

and any other public officials. 

I. Any incident, accident or flight operation that transgresses the latera l or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA's UAS 

Integration Office (AFS-80) within 24hrs. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

9 
www.ntsb.com. GeoSky3 will suspend all flight operations until the incident, accident, or 

transgression is reviewed by AFS-80 and authorization to resume operations is provided. 

14 CFR Part 11.81 (Q A summary the FAA can publish in the Federal Registet·, stating: 

(I) The rule from which you seck the exemption Petitioner: GeoSkv3 14 CFR and FAA regulations 

tha t GeoSkv3 seeks an exemption: 

14 CFR Part 2 1 Subpart H 

14 CFR Part 45.23 (b) 

14 CFR Part 6 1. 113 (a) and (b) 

14 CFR Part 91.7 

14 CFR Part 9 1.9 (b) 

14 CFR Part 9 1. 1 09 

14 CFR Part 9 1. 119 

14 CFR Part 9 1. 121 

14 CFR Part 91. 151 

14 CFR Part 91.203 (a) and (b) 

14 CFR Part 91.405 

14 CFR Part 91.407 

14 CFR Part 91.409 

14 CFR Part 91.4 17 U.S. DOT-FAA-Air Traffic Organization Policy Notice N JO 7210.873 (6.d) 

(2) A brief description of the nature of the exemption you seek: 

GeoSky3 seeks re lief from the applicable parts of 14 CFR 2 1, 45, 61 , 91 and U.S. DOT-FAA-Air Traffic 

Organization Policy Notice N JO 7210.873 (6.d) as requested within this petition to allow GeoSky3 to 

safely and effi ciently conduct civil UAS flight operations. This will have an immediate and positive impact 

by providing enhanced services and experience while providing safer and environmentally e ffic ient service 

by dismissing the use of manned helicopters and their emissions. This new avenue of intelligence will, in a 

positive way, impact the publics' interest with a complete evaluation of their security and less of an 

environmental impact from manned aircraft, emissions and the fatal inj uries they represent 

14 CFR Part 11.81 (g) - Any additiona l information, views or arguments avaiht ble to support 

GeoSkv3's req uest: 

This exemption would allow GeoSky3 to provide security services, real estate photography and Geographic 

Information Systems (GIS) for business, personal and communities as a whole. Additional development 

and operations would benefit not only GeoSky3 and it's communities, but would allow GeoSky3 to serve 

as a partner with the FAA and others within the UAS community to advance this new and emerging 

technology in a safe and controlled environment. GeoSky3 has demonstrated the value of our request to 

utilize our UAS technology and in productive and safe manner within the FAA guidelines. 

14 CFR Pa rt 11.81 (h) - Req uest to exercise the privileges of the exemption outside the United States, 

the reason whv the petitioner needs to do so: 

GeoSky3 docs not seck to exercise the privileges of this exemption, shou ld it be granted, outside of the 

United States. Our request is strictly to be granted authority for civil UAS operations at locations within the 

national airspace system. 

Sincerely, 

Stavros G. Georgeadis 

Member 

GeoSky3 LLC 

10 
EASY, SAFE FLIGHT 

INSPIRE 1 

Ont' But:on 

Ta<~OII 

H 

' . ~ Dynamic Home Point 

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