GrandView Services, LLC

208 Sequoia Avenue

Walnut Creek, CA 94595

925-932-6305

heller@grandview.biz

Public docket No. FAA-2015-0582

April 20, 2015

Federal Aviation Administration

800 Independence Ave., S.W.

Washington, D.C. 20591

Dear Mr. Troutman,

I received your letter dated March 24, 2015 regarding my FAA Part 333 exemption request for

GrandView Services, LLC. The letter was incorrectly addressed to “Mr. Gregory.” However, I

am actually a woman, so please correct this in all future correspondence.

In the March 24, 2015 letter you indicated that additional information was needed to

supplement GrandView’s original application which was submitted on March 6, 2015. The

additional information needed was identified as::

● “The reasons why granting the request would be in the public interest;that is, how it

would benefit the public as a whole.”

● “Any additional information, views, or arguments available to support your request.”

In response to the letter I am resubmitting a revised Part 333 exemption request for

GrandView Services, LLC (see attached letter). The revised exemption request includes the

information included in our original request plus the additional information requested in your

letter. I have also attached a pdf copy of the manuals for the UAS vehicles referenced in our

revised exemption request.

We trust that the additional information provided in response to your letter will be sufficient for

review of GrandView’s requested exemption. Thank you for your consideration of this revised

requested exemption.

Yours truly,

Helleren Gregory, President

GrandView Services, LLC
April 20, 2015

800 Independence Ave., S.W.

Washington, D.C. 20591

Dear Mr. Troutman,

GrandView Services, LLC is filing this petition for exemption with the FAA regarding Title 14

of the Code of Federal Regulations (CFR). This request is being made is pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (Public law 122­95).

GrandView Services, LLC is a woman­owned small business that is focused primarily on UAS

vehicle based data collection and processing for geotechnical and civil engineering purposes

in California. The company’s processes are being developed through coordination with Cal

Engineering & Geology, Inc. (CE&G), a 22 year old geotechnical and civil engineering

consulting firm in the San Francisco Bay Area. GrandView is working closely with CE&G to

fine tune the specific applications of UAS vehicle data collection processes to be used with

the services provided by CE&G and other similar engineering consulting companies in

California. The two companies are also working together to develop related applications of the

the data collection that can be used in monitoring and maintenance of public infrastructure as

diverse as roads, levees, flood control channels, parks, and golf courses.

We are specifically requesting exemptions from the following items in the FAR/AIM rules and

procedures: Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2) and 91.417(a) & (b). The requests for exemption from each of the

identified sections concern commercial operation of 3D Robotics Iris+ and 3D Robotics X8M

UAS vehicles.

Planned Use of UAS Vehicles by GrandView

GrandView Services’ planned use of the UAS vehicles will focus on collection of digital

geospatial data for use in land form modeling, land surveying, and monitoring for civil and

geotechnical engineering, environmental management, and infrastructure asset and

maintenance applications. The 3D Robotics Iris+ UAS is equipped with a GoPro 4 digital

camera and the X8M will be equipped with a digital single lens reflex (DSLR) camera for

higher resolution and increased accuracy for photogrammetry and mapping. Additional other

similar UAS’s may be purchased in the future to be used for collecting higher resolution

geospatial digital data and for use with compact lightweight LiDar scanning modules. We feel

that the use of UASs in the engineering fields noted will enhance data collection for existing

sites and for monitoring of site conditions following natural disasters. We will operate

specifically in this business sector. GrandView will focus on making the above described

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services available to private engineering and consulting firms and public agencies who might

otherwise be unlikely to file for their own exemptions or to create their own geospatial data

collection department within their current business or agency.

GrandView does not plan on utilizing the UAS vehicles for transport of materials or products

at any time.

Operations of UAS Vehicles by GrandView

GrandView Services will comply with all aspects of currently proposed and future FAA rulings

regarding the commercial use of UASs. We understand that the currently proposed FAA rules

are as follows:

● A small UAS operator must always see and avoid manned aircraft. If there is a

risk of collision, the UAS operator must be the first to maneuver away.

● The operator must discontinue the flight when continuing would pose a hazard

to other aircraft, people or property.

● A small UAS operator must assess weather conditions, airspace restrictions

and the location of people to lessen risks if he or she loses control of the UAS.

● A small UAS may not fly over people, except those directly involved with the

flight.

● Flights should be limited to feet altitude 200 feet AGL and no faster than 100

mph.

● Operators must stay out of airport flight paths and restricted airspace areas,

and obey any FAA Temporary Flight Restrictions (TFRs).

GrandView Services president Ms. Helleren Gregory is current with these proposed

regulations and as a private pilot is also aware of current FAA regulations regarding

limitations in Class A,B,C, & D airspace along with weather minimums for safe flight. When

planning each UAS flight, GrandView will have and utilize current charts along with making

use of access to DUATS, an AOPA membership, and TFR notifications.

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Safe UAS Operation

To ensure safety, the UAS vehicles for which we are requesting exemptions will be operated

initially by GrandView Services’ founder and president, Ms. Helleren Gregory. She is a

licensed private pilot and will serve as the company’s Pilot in Command (PIC). Ms. Gregory

has taken the written knowledge test within the two year recent proposed time limit of the FAA

written test taken and passed in June, 2014. GrandView Services’ future UAS pilots/operators

will go through training and testing as deemed appropriate and required by the FAA, including

both written and practical tests that will apply. Ms. Gregory will also personally train/test any

and all potential future GrandView pilots prior to allowing them to operate a GrandView UAS.

The operation of GrandView’s UAS vehicles will be covered by general liability insurance

once we begin commercial use. We have been offered liability insurance through

Transportrisk.com and will obtain insurance from that firm or another similar firm. The

insurance policy will include liability coverage and limited loss/damage coverage for the UAS

vehicles themselves. The insurance underwriters have informed GrandView that they will

require that identification/tracking stickers be placed on each vehicle and that in order to

obtain insurance we will be requested to develop and follow written operation and safety

guidelines. The two UAS vehicles will carry a liability insurance policy with limited damage

and recovery.

Public Benefit

The exemptions requested by GrandView will benefit the public in general and more

specifically in the practice of civil and geotechnical engineering, environmental management,

and infrastructure asset and maintenance applications. Geospatial data collection using UAS

vehicles for these applications enhances public safety and allows for better management of

critical infrastructure and environmental assets.

Overall, the public will benefit through:

● decreased response times related to the identification, monitoring, and abatement of

landslides and other geologic hazards that threaten public safety and property

● improved quality and repeatable monitoring of public infrastructure and environmental

assets including levees, roads, and waterways,

● time lapse data collection for evaluation and management of environmental

restoration.

● dramatically improved safety during inspection and observation of steep hillsides and

similar limited access areas which would otherwise be inaccessible or only be

accessible by rock climbing or other very dangerous means.

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Specifics of Exemptions Requested

GrandView Services LLC is seeking exemption from the rules included in Sections 61.3(a)

and (b), 61.113(a),(b), and (c), 61.133(a), 91.7, 91.121(a), 91.151, 91.405(a), 91.407,

91.409(a)(1) & (a)(2) and 91.417(a) & (b) noted below. Commentary regarding how each of

the exemptions requested apply to GrandView’s commercial services are provided in italics.

61.3 Requirement for certificates, ratings, and authorized pilot certificate.

(a) Pilot certificate. No person may serve as a required pilot flight crewmember of a civil

aircraft of the United States, unless that person—

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in that

person's physical possession or readily accessible in the aircraft when exercising the

privileges of that pilot certificate or authorization. However, when the aircraft is operated

within a foreign country, a pilot license issued by that country may be used; and

(2) Has a photo identification that is in that person's physical possession or readily accessible

in the aircraft when exercising the privileges of that pilot certificate or authorization. The photo

identification must be a:

(i) Driver's license issued by a State, the District of Columbia, or territory or possession of the

United States;

(ii) Government identification card issued by the Federal government, a State, the District of

Columbia, or a territory or possession of the United States;

(iii) U.S. Armed Forces' identification card;

(iv) Official passport;

(v) Credential that authorizes unescorted access to a security identification display area at an

airport regulated under 49 CFR part 1542; or

(vi) Other form of identification that the Administrator finds acceptable.

(b) Required pilot certificate for operating a foreign­registered aircraft. No person may serve

as a required pilot flight crewmember of a civil aircraft of foreign registry within the United

States, unless that person's pilot certificate—

(1) Is in that person's physical possession, or readily accessible in the aircraft when exercising

the privileges of that pilot certificate; and

(2) Has been issued under this part, or has been issued or validated by the country in which

the aircraft is registered.

GrandView requests exemption from this section so that a private pilot license held by

Helleren Gregory may be used for profit only with GrandView’s UAS vehicles to collect

data. The exemption request does not include transport of passengers or property nor

does it include single engine planes.

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61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a

private pilot certificate may act as pilot in command of an aircraft that is carrying passengers

or property for compensation or hire; nor may that person, for compensation or hire, act as

pilot in command of an aircraft.

(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in

connection with any business or employment if:

(1) ​The flight is only incidental to that business or employment; and

(2) ​The aircraft does not carry passengers or property for compensation or hire.

(c) A private pilot may not pay less than the pro rata share of the operating expenses of a

flight with passengers, provided the expenses involve only fuel, oil, airport expenditures, or

rental fees.

GrandView and PIC Helleren Gregory will utilize UAS vehicles solely as a tool to collect

data and not to carry passengers or property. We therefore request an exemption to

this section.

61.133 Commercial pilot privileges and limitations.

(a) Privileges—

(1) General. A person who holds a commercial pilot certificate may act as pilot in command of

an aircraft—

(i) Carrying persons or property for compensation or hire, provided the person is qualified in

accordance with this part and with the applicable parts of this chapter that apply to the

operation; and

(ii) For compensation or hire, provided the person is qualified in accordance with this part and

with the applicable parts of this chapter that apply to the operation.

GrandView requests an exemption from this section to allow GrandView and PIC

Helleren Gregory, who holds a private pilot license, to act as pilot in command of UAS

vehicles for hire to collect data but not to carry persons or property for hire.

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91.7 Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

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

is in condition for safe flight. The pilot in command shall discontinue the flight when

un­airworthy mechanical, electrical, or structural conditions occur.

Currently, there is no airworthiness registration process for UAS vehicles. The 3D

Robotics Iris+ UAS and the X8M UAS which will be used initially by GrandView are

commercially available vehicles that have been developed and tested extensively. A

copy of the User’s Manual for the 3D Robotics Iris+ is appended to this letter.

To ensure airworthiness and flight safety prior to each flight, GrandView’s PIC will

perform the recommended checklist procedure included in the user’s manuals and as

recommended for each UAS.

If registering a UAS in the future is a requirement, GrandView will comply. If necessary,

GrandView will also apply for a special airworthiness certificate in the experimental

category under Title 14 of the Code of Federal Regulations (14 CFR) § 21.191 for the

purposes of research and development, crew training, or market survey. We will also

apply for type certification under § 21.17(b) (for a standard airworthiness certificate in

the special class category) or § 21.25 (for a special airworthiness certificate in the

restricted category).

91.121 Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 nautical

miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the

current reported altimeter setting of an appropriate available station; 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.

GrandView requests exemption from these requirements but will comply with the

height and weight requirements proposed by the FAA on February 15, 2015, or as

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modified in the future. The currently proposed requirements restrict UAS operation to

below 200 feet above ground level and outside of the airspace described in 91.121.

91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane under VFR conditions unless (considering

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended

landing and, assuming normal cruising speed—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind

and forecast weather conditions) there is enough fuel to fly to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

Battery operated flight time for the 3DR Iris+ and X8M UAS vehicles initially being used

by GrandView is approximately ten minutes. Both the 3DR Iris+ and X8M flight control

systems includes battery life / flight time alert features which provide warnings of

limited flight time remaining as well as a RTL (return to land) automatically when

battery is low. Future flight times for other UASs anticipated to be used by GrandView

will vary but are expected to have similar limitations and similar alert capabilities.

In addition, GrandView’s UAS vehicles will be flown in accordance with line of sight

and weather minimums designated for UAS vehicles as proposed by the FAA on

February 15, 2015 and as modified in the future. Therefor VFR equivalent conditions

will apply.

91.405 Maintenance required.

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between

required inspections, except as provided in paragraph (c) of this section, have discrepancies

repaired as prescribed in part 43 of this chapter;

(b) Shall ensure that maintenance personnel make appropriate entries in the aircraft

maintenance records indicating the aircraft has been approved for return to service;

(c) Shall have any inoperative instrument or item of equipment, permitted to be inoperative by

§ 91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required

inspection; and

(d) When listed discrepancies include inoperative instruments or equipment, shall ensure that

a placard has been installed as required by § 43.11 of this chapter.

GrandView seeks exemption from maintenance required of a single engine plane. We

will comply with manufacturer recommended maintenance and maintenance as

required of a UAS vehicle by the FAA when that is mandated.

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91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 of this

chapter; and

(2) The maintenance record entry required by § 43.9 or § 43.11, as applicable, of this chapter

has been made.

(b) No person may carry any person (other than crewmembers) in an aircraft that has been

maintained, rebuilt, or altered in a manner that may have appreciably changed its flight

characteristics or substantially affected its operation in flight until an appropriately rated pilot

with at least a private pilot certificate flies the aircraft, makes an operational check of the

maintenance performed or alteration made, and logs the flight in the aircraft records.

(c) The aircraft does not have to be flown as required by paragraph (b) of this section if, prior

to flight, ground tests, inspection, or both show conclusively that the maintenance, preventive

maintenance, rebuilding, or alteration has not appreciably changed the flight characteristics or

substantially affected the flight operation of the aircraft.

GrandView seeks exemption from the requirements of this section until such time that

FAA requirements specific to UAS vehicles are developed and approved. In the

meantime, we will comply with manufacturer recommended maintenance and pre­flight

check guidelines for ensuring flight safety.

91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft

unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for

return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of

this chapter.

No inspection performed under paragraph (b) of this section may be substituted for any

inspection required by this paragraph unless it is performed by a person authorized to perform

annual inspections and is entered as an “annual” inspection in the required maintenance

records.

(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft

carrying any person (other than a crewmember) for hire, and no person may give flight

instruction for hire in an aircraft which that person provides, unless within the preceding 100

hours of time in service the aircraft has received an annual or 100­hour inspection and been

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approved for return to service in accordance with part 43 of this chapter or has received an

inspection for the issuance of an airworthiness certificate in accordance with part 21 of this

chapter. The 100­hour limitation may be exceeded by not more than 10 hours while en route

to reach a place where the inspection can be done. The excess time used to reach a place

where the inspection can be done must be included in computing the next 100 hours of time

in service.

(c) Paragraphs (a) and (b) of this section do not apply to—

(1) An aircraft that carries a special flight permit, a current experimental certificate, or a

light­sport or provisional airworthiness certificate;

(2) An aircraft inspected in accordance with an approved aircraft inspection program under

part 125 or 135 of this chapter and so identified by the registration number in the operations

specifications of the certificate holder having the approved inspection program;

(3) An aircraft subject to the requirements of paragraph (d) or (e) of this section; or

(4) Turbine­powered rotorcraft when the operator elects to inspect that rotorcraft in

accordance with paragraph (e) of this section.

GrandView seeks exemption from the requirements of this section until such time that

FAA requirements specific to UAS vehicles are developed and approved. In the

meantime, we will comply with manufacturer recommended maintenance and pre­flight

check guidelines for ensuring flight safety.

91.417 Maintenance records.

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered

owner or operator shall keep the following records for the periods specified in paragraph (b) of

this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the

100­hour, annual, progressive, and other required or approved inspections, as appropriate, for

each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an

aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work performed;

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to

service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life­limited parts of each airframe, engine, propeller, rotor, and

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection

required by the inspection program under which the aircraft and its appliances are maintained.

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(v) The current status of applicable airworthiness directives (AD) and safety directives

including, for each, the method of compliance, the AD or safety directive number and revision

date. If the AD or safety directive involves recurring action, the time and date when the next

action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is

repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred

with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter

shall be retained until the defects are repaired and the aircraft is approved for return to

service.

(c) The owner or operator shall make all maintenance records required to be kept by this

section available for inspection by the Administrator or any authorized representative of the

National Transportation Safety Board (NTSB). In addition, the owner or operator shall present

Form 337 described in paragraph (d) of this section for inspection upon request of any law

enforcement officer.

GrandView seeks exemption from the requirements of this section until such time that

FAA requirements specific to UAS vehicles are developed and approved. In the

meantime, we will comply with manufacturer recommended maintenance and pre­flight

check guidelines for ensuring flight safety.

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Conclusions

The commercial service that GrandView Services LLC plans to provide using UAS vehicles

equipped with digital cameras and other data collection systems will support the practice of

civil and geotechnical engineering, environmental management, and infrastructure asset and

maintenance applications. Geospatial data collection using UAS vehicles for these

applications 1) enhances public safety and 2) allows for better management of critical

infrastructure and environmental assets. In addition, UAS vehicles operated by GrandView

will provide a cost effective and safe means of collecting data which otherwise may be very

expensive and dangerous to obtain or may not be obtainable at all.

GrandView will be able to ensure safe operation and use of the UAS vehicles by adhering to

all FAA guidelines and regulations as they are developed for UAS vehicles and by following

the guidelines of good general aviation practices that PIC Helleren Gregory has learned as a

licensed private pilot. GrandView and Ms. Gregory are working closely with and participating

in the organizations and companies that are currently and rapidly developing the operational,

safety, and applications aspects of small UAS vehicles. Because of this, as updated

operational, safety, and applications are introduced, GrandView will be aware of, and will

follow, changes to the federal, state, and local regulations as they develop. Granting the

exemptions requested by GrandView will benefit the public interest as GrandView will use

UAS vehicles to provide more cost effective, safe, and environmentally friendly means of

planning, designing, completing, and maintaining projects.

In addition, granting of the exemptions will be beneficial to the general public by providing an

opportunity for a small women­owned business to compete in an business sector which has

historically had a relative high start­up cost. With the exemptions GrandView will be a small

business that can compete with much larger firms that have the ability to invests hundreds of

thousands of dollars or more. Through services like GrandView, the cost to provide valuable

data for the public infrastructure engineering, constructions, and maintenance sectors will fall

dramatically with increased competition presented by the smaller firms like GrandView.

Sincerely,

Helleren Gregory, President

GrandView Services, LLC

Attachments: PDF manuals (POH) of both Iris+ and X8M manufactured by 3DRobotics PDF

of letter received by FAA

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