July 30, 2015

Exemption No. 12243

Regulatory Docket No. FAA–2015–2032

Ms. Michelle Urlacher

GeoStabilization International, LLC

543 31 Road

Grand Junction, CO 81504

Dear Ms. Urlacher:

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.

By letter dated May 18,2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of GeoStabilization International, LLC (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial acquisitions and research.

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 Phantom 3.

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 
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finds that 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 collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 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 Labs, 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, GeoStabilization International, 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.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, GeoStabilization International, LLC is hereafter referred to as 

the operator.

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 Phantom 3

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, 
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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 

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.
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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 

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 

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 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.
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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.

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.
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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.

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.
8

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

GEOSTABILIZATION INTERNATIONAL, LLC 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF THE 

DJI PHANTOM 3 UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 <PUBLIC LAWJ12-95l 

Submitted on May 18,2015 

GeoStabilization 

International, LLC 

543 31 Rd 

Grand Junction, CO 81504 

Tel: (970) 210-6170 

Fax: (970) 245-7737 
INTRODUCTION AND INTERESTS OF PETITIONER ............................................................... .4 

BACKGROUND ...................................................................................................................... 4 

BASIS FOR PETITION ............................................................................................................. 6 

NAME AND ADDRESS OF PETITIONER ................................................................................... 7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH GEOSTABILIZATION 

INTERNATIONAL,LLC SEEKS EXEMPTION ............................................................................... 8 

THE EXTENT OF RELIEF GEOSTABILIZATION INTERNATIONAL SEEKS AND THE REASON 

GEOSTABILIZATION INTERNATIONAL SEEKS THE RELIEF 11 

THE REASONS WHY GRANTING GEOSTABILIZATION INTERNATIONAL'S REQUEST WOULD 

BE IN THE PUBLIC INTEREST 

............................................................................................................................................. 1 

3 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY 

............................................................................................................................................. 1 

7 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER ....................................... 33 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT 

GEOSTABILIZATION INTERNATIONAL LLC REQUEST 

............................................................................................................................................. 4 

33 

CONCLUSION ..................................................................................................................... 34 

2 
ATO 

AV 

C.F.R. 

COA 

FAA 

FAR 

GCS 

NAS 

NOT AM 

PIC 

Section 333 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

vo 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulation 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

National Airspace System 

Notice to Airmen 

Pilot In Command 

FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Sight 

Visual Meteorological Conditions 

Visual Observer 

3 
Modernization and Reform Act of 2012 (FMRA). This exemption will permit GeoStabilization 

International, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial acquisitions and research within the National Airspace System (NAS). 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

GeoStabilization International, LLC (hereinafter referred to as "GSI") is focused on providing 

solutions for utilizing unmanned aircraft to safely and efficiently collect data that is precise, 

accurate, and timely. GSI's mission is to use unmanned aircraft to simplify and increase the 

effectiveness of data collection for the purpose of more efficient and effective imaging and 

classification of geohazards in order to better understand and design better mitigation strategies 

for geotechnical hazards throughout the United States that threaten infrastructure (roads, 

pipelines, homes, etc) 

As set forth in this Petition, GSI seeks to commercially operate its DJI PHANTOM 3 UAS 

within the NAS for the purpose of conducting aerial acquisitions and research for geotechnical 

hazards. 

BACKGROUND 

Unmanned Aircraft System: DJI PHANTOM 3 

GSI seeks an exemption to operate the DJI PHANTOM 3 UAS, for compensation or hire 

within the National Airspace System ("NAS"). The DJI PHANTOM 3 UAS is comprised of an 

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be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R. 

Part 47, Aircraft Registration. 

Figure 1: The DJI PHANTOM 3 UA. 

BASIS FOR PETITION 

Petitioner, GeoStabilization International, LLC pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, 

5 
In consideration of the size, weight, speed, and limited operating area associated with 

the unmanned aircraft and its operation, GSI's operation of the DJI PHANTOM 3 UAS meets the 

conditions of Section 333 and will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. 

Therefore, GSI requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate. 

GSI submits that the requested relief is proper since an equivalent level of safety will 

be ensured GSI will use its technicians to perform maintenance, alterations, or preventive 

maintenance on the unmanned aircraft system using the methods, techniques, and practices 

prescribed in the manufacturer's maintenance manual. Furthermore, GSI will document and 

maintain all maintenance records for the DJI PHANTOM 3 UAS. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by GSI to the extent necessary to a · 

qualified GSI employee or consultant who has completed the DJI PHANTOM 3 UAS training, to 

conduct the proposed UAS operations. GSI's UAS program will be overseen and supervised by 

employee licensed private pilots, who will provide initial internal GSI-UAS Operations Certification 

training as well as ongoing oversight and continuing education and training regarding flight and 

operations protocol consistent with their training. GSI submits that the conditions and limitations 

set forth herein will ensure the safety of the NAS, as well as the safety of persons or property on 

6 
airworthy condition, prior to every flight, by determining that the UAS is in compliance with the 

DJI PHANTOM 3 UAS Operator Manual and that the UAS is in condition for safe flight. 

GSI also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, because the altitude reporting equipment of the DJI PHANTOM 3 UAS is set to a 

pressure level of zero feet above ground level (AGL), rather than local barometric pressure 

or field altitude, before each flight. A level of safety equivalent to Section 91.121 will be 

ensured as the altitude of the DJI PHANTOM 3 UA will be reported to air traffic control 

(ATC) in feet AGL, and GSI will operate the DJI PHANTOM 3 UA within visual line of sight, at 

or below 400 feet AGL. 

GSI also seeks an exemption from the requirements of Section 91.151(a)(1), Fuel 

requirements for flight in VFR conditions. GSI submits that safety will not be affected by 

terminating flights of the battery powered DJI PHANTOM 3 UA after 13 minutes of continuous 

operation, with 10 minutes remaining battery power. 

In accordance with 14 C.F.R. § 11.81, GSI provides the following information in support of 

its petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner is: 

GeoStabilization International, LLC 

543 31 Rd 

Grand Junction, CO 81504 

The point of contact for this Petition and specific contact information is as follows: 

Michelle Urlacher 

GeoStabilization International, LLC 

543 31 Rd 

Grand Junction, CO 81504 

Tel: (970) 210-6170 I Fax: (970) 245-7737 

7 
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subsections (a) and (b) prescribe the following, in part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC 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. 

2. GSI Seeks Exemption From The Requirements Of Section 91. 7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

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

3. GSI Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in relevant 

part: 

(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 

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states the following: 

(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 15 minutes[.] 

5. GSI Seeks Exemption From The Requirement Of Section 91.40S(a). Section 

91.405, entitled Maintenance required, subsection (a), states the following: 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) ofthis section, have 

discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. GSI Seeks Exemption From The Requirements Of Section 91.407(a)(1). 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(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 § 

43.7ofthis chapter[.] 

7. GSI Seeks Exemption From The Requirements Of Sections 91.409(a)(1} And 

91.409(a)(2}. 

Section 91.409, entitled Inspections, subsection (a), states the following: 

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

9 
8. GSI Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (bL state the 

following: 

(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) ofthis section: 

(1) Records ofthe maintenance, preventive maintenance, and alteration and 

records of the 100-hour, 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; and 

(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 life-limited 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 

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(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)(l) ofthis 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. 

B. The Extent Of Relief GSI Seeks And The Reason GSI Seeks The Relief. 

1. Extent of Relief GSI Seeks And The Reason GSI Seeks Relief From Section 

61.113(a) And (b). 

Relieffrom Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot 

in command, is requested to the extent necessary to allow a PIC who has completed the Phantom 

3 UAS training requirements, to conduct the proposed UAS flight operations for compensation. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

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

The aircraft does not carry passengers or property for compensation or hire. 

11 
specifications as described in this exemption, including evasive and emergency maneuvers, as 

well as maintaining appropriate distances from people, vessels, vehicles and structures. 

Further, GSI submits that all flights of the DJI PHANTOM 3 UAS, conducted by the PIC 

pursuant to the grant ofthis Petition will be: (1) incidental to GSI's business; and (2) not carry 

passengers or property for compensation or hire. 

2. Extent of Relief GSI Seeks And The Reason GSI Seeks Relief From Section 

91.7(a). 

Relief from Section 91. 7(a), entitled Civil aircraft airworthiness, is requested to the 

extent required to allow GSI to determine that the DJI PHANTOM 3 UAS is in an airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the DJI PHANTOM 3 

UAS Operator Manual and that the UAS is in condition for safe flight. Copies of the manuals, 

which contain proprietary information, are attached hereto as Exhibits A. respectively, and are to 

be held in a separate file pursuant to 14 C.F.R. § 11.35(b). 

GSI seeks the requested relief because the DJI PHANTOM 3 UAS does not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, GSI will 

ensure that the DJI PHANTOM 3 UAS is in an airworthy condition based upon its compliance with 

the operating documents prior to every flight, and as stated in the conditions and limitations 

below. 

3. Extent Of Relief GSI Seeks And The Reason GSI Seeks Relief From Sections 

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fully below, the DJI PHANTOM 3 UAS meets the conditions of Section 333 for operation without 

an airworthiness certificate. Accordingly, GSI will use technicians to perform maintenance, 

alterations, or preventive maintenance on the unmanned aircraft system using the methods, 

techniques, and practices prescribed in the manufacturer's maintenance manual. Furthermore, 

GSI will document and maintain all maintenance records for the DJI PHANTOM 3 UAS. 

C. The Reasons Why Granting GSI's Request Would Be In The Public Interest; 

That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing GSI to safely, 

efficiently, and economically perform aerial acquisitions and research within the NAS, 

commercially, in support of researching geotechnical hazards, which threaten public and private 

infrastructure. Additionally, use ofthe DJI PHANTOM 3 UAS will decrease congestion ofthe NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of the 

proposed operation of the DJI PHANTOM 3 UAS will be realized without implicating any privacy 

issues. 

1. The Public Will Benefit From The Aerial Acquisition And Research 

Performed. 

GSI submits this Petition to commercially operate the DJI PHANTOM 3 UAS and perform 

aerial acquisition and research within the NAS, in support of government entities, transportation 

departments, agriculture, scientific studies, wildlife monitoring, forestry, mining, and the oil 

13 
how the requested exemption will directly benefit the above-referenced industries and the 

public. The DJI Phantom 3 will be used to reach previously inaccessible areas to image and map 

potential geotechnical risks to the public. The DJI Phantom will give our crew the safe approach of 

being able to monitor potential landslides, rockfall areas and other potential geohazard 

situations that are a potential risk to the public. 

2. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI PHANTOM 3 UA is battery powered and serves as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the 

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use 

of a DJI PHANTOM 3 UAS would reduce the amount of manned aircraft in the NAS, reduce noise 

and air pollution, as well as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The DJI 

PHANTOM 3 UA does not require an airport to takeoff or land. Likewise, a reduction of manned 

aircraft conducting aerial survey missions would result in fewer aircraft that must be handled by 

air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations. 

3. The Public Will Benefit From The Safety And Efficiency Of The DJI PHANTOM 3 

UAS. 

14 
, 

p

p

, 

environmentally conscious alternative to the cabin class, six cylinder internal combustion twin 

engine aircraft that are typically utilized for aerial acquisitions, while burning approximately 20-

30 gallons per hour of leaded aviation fuel. The DJI PHANTOM 3 UA, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as its battery powered electric 

motor is barely audible during the take-off phase, and cannot be heard when operating more 

than 100 feet above ground level. 

By using the DJI PHANTOM 3 UAS to perform aerial acquisitions, the substantial risk to 

life and property in the air and on the ground, which is usually associated with traditional 

manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside 

from the lack of aircrew members located on board the aircraft, the DJI PHANTOM 3 

UA(weighing approximately 1,280g at its maximum gross weight with a Diagonal Size 590mm, 

with no fuel on board), has less physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that typically conduct aerial 

acquisitions (weighing approximately 6,500 pounds with a wingspan of approximately 40 feet, a 

length of 34 feet, and a fuel capacity of 180 gallons). 

Furthermore, by using the DJI PHANTOM 3 UAS to perform aerial acquisitions of 

potential geotechnical risks to the public we are able to quickly, and efficiently access emergency 

situations and develop a design-build approach to remedy such geohazard risks. 

15 
and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel 

and the Environmental Protection Agency ("EPA") regulatory actions phasing out leaded fuels, 

U.S. owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered DJI PHANTOM 3 UAS is one such 

technology that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional manned 

aircraft. 

By operating the DJI PHANTOM 3 UAS, companies such as GSI can remain competitive 

and profitable, and therefore provide greater job stability to employees and contractors, which 

will ultimately contribute to growth of the U.S. economy. Improved financial performance of 

U.S. companies, through commercial use ofthe DJI PHANTOM 3 UAS, provides a stable 

workforce that increases consumer spending; improves local, state, and federal tax revenues; 

and allows companies to invest in research and development in order to remain competitive 

both in the United States and abroad. 

5. There Are No Privacy Issues. 

Like the manned aerial acquisition flight operations that have been conducted for 

decades, the proposed operation of the DJI PHANTOM 3 UAS will not implicate any privacy 

issues. 

16 
How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided 

By The Rule From Which GSI Seeks Exemption. 

1. Reasons Why The OJI PHANTOM 3 UAS Meets The Conditions Of The FAA 

Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with 

the unmanned aircraft and its operation, GSI's operation ofthe DJI PHANTOM 3 UAS meets 

the conditions of FMRA Section 333, and will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users ofthe 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 

333 states the following, in part: 

(a) In Generai.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 

of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--ln making the determination 

under subsection (a}, the Secretary shall determine, at a minimum--

(1) ) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national 

security; and 

17 
national airspace system. 

In seeking this exemption, GSI submits that the DJI PHANTOM 3 UAS can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the safe operational history and 

current use ofthe DJI PHANTOM 3 UAS in the NAS; (b) the characteristics of the DJI PHANTOM 3 

UAS; (c) the private pilot certification requirement; and (d) the specific operating limitations. 

a. The OJI PHANTOM 3 UAS Has A Proven History Of Operation In The 

NAS. 

The DJI Phantom 3 utilizes four (4) counter-rotating propellers paired oppositely to each other for 

balance, control and stability. The total spanofthe 

UAS 6 590mm including propellers, allowingfor stable flight or landing even with the sudden onset 

of detrimental environmental conditions. The 

UASs maximum weight (including battery, propellers) of 13 Kg. The applicant's UAS is designed to 

hover in place to capture photographic data and then operate at less than 50 knot maximum 

speed to the next point of Interest. They are capable of vertical and horizontal operations but, in 

practice, is operated only within unaided VLOS ofthe PIC. In addition to the PIC, the Applicant employs 

a spotter (VOS role) and a technician (secondaryVOSandonsitepersonnelliaison)which are within 

verbal communication range. In the eventoflossofvisual ofthe UASthe PJCcan change the flight 

controls from Cartesian (X,Y,Z.) based controls to radial (r,a,h) based controls which allows the PICto 

utilize one controller axis to recall the UAStothe PIC's position without concern to the current 

headingofthe UASs. The UASs also have a Return-to-Home feature that will allow the UAS to return to 

the PIC's location inthe case of the UAS bsingsignal to the PIC, or fthe PIC initiates the Return-toHome procedure. In the event of loss of sight of the UASs into an area containing hazards or possible 

hazards, the spotter has a heads-up-display containing a live video feed which can be used to locate 

the UAS while it maintains its position hover mode. The UAS has demonstrated its ability to maintain 

its position byGPS, SONAR, and Optical flow camera with an accuracy of+/- lOcm vertical and +1-

1m horizontal. 

All oft he applicant's UAS' s utilize LiPo (lithium polymer) battery based power sources, decreasingsafety 

risks from more easily combustible, fuel based, power sources. Flighttimes generally last between 

18 
b. The Specifications Of The DJI PHANTOM 3 UAS Demonstrate Its Safe 

Characteristics. 

The DJI PHANTOM 3 UAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability. 

Technical Specifications Of The DJI PHANTOM 3 UAS. 

Aircraft 

Weight (Including Battery And Propellers) 

1280g 

Diagonal Size (Including Propellers) 

590mm 

Max Ascent Speed 

5 m/s 

Max Descent Speed 

3 m/s 

Hover Accuracy 

Vertical: +/- 10cm 

Horizontal: +/- 1m 

Max Speed 

16 m/s (ATTI mode, no wind) 

Max Altitude Above Sea Level 

6000m 

Operating Temperature 

ooc to 40°C 

GPS Mode 

GPS/GLONASS 

Camera 

Sensor 

Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) 

Lens 

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at oo 

19 
Single Shot 

Burst Shooting: 3/5/7 shots 

Auto Exposure Bracketing (AEB): 3/5 

Bracketed Frames at 0. 7EV Bias 

Time-lapse 

Video Recording Modes 

Phantom 3 Professional 

UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 

FHD: 1920x1080p 24/25/30/48/50/60 HD: 1280x720p 24/25/30/48/50/60 

Phantom 3 Advanced 

FHD: 1920x1080p 24/25/30/48/50/60 HD: 1280x720p 24/25/30/48/50/60 

Supported SD Card Types 

Micro SD 

Max capacity: 64GB. Class 10 or UHS-1 rating required 

Max Bit rate Of Video Storage 

Phantom 3 Professional 

60 Mbps 

Phantom 3 Advanced 

40 Mbps 

Supported File Formats 

FAT32/exFAT 

Photo: JPEG, DNG 

Video: MP4, MOV (MPEG-4 AVC/H.264) 

Operating Temperature 

ooc to 40°C 

Gimbal 

Controllable Range 

Pitch -90° to +30° 

Stabilization 

3-axis (pitch, roll, yaw) 

20 
Operating Environment 

Surface with clear pattern and adequate lighting (Lux> 15) 

Remote Controller 

Operating Frequency 

2.400 GHz-2.483 GHz 

Max Distance 

2000m (outdoors and unobstructed) 

Video Output Port 

USB 

Operating Temperature 

0°C- 40°C 

Battery 

6000 mAh LiPo 2S 

Mobile Device Holder 

For tablet or phone 

Receiver Sensitivity (1%PER) 

-101 dBm ±2 dBm 

Transmitter Power (EIRP) 

FCC: 20 dBm 

CE: 16 dBm 

Working Voltage 

1.2 A @7.4 V 

Battery Charger 

Voltage 

17.4 v 

Rated Power 

Phantom 3 Professional 

100W 

Phantom 3 Advanced 

57W 

Intelligent Flight Battery 

Capacity 

4480 mAh 

21 
g 

Max Flight Time 

Approximately 23 minutes 

Operating Temperature 

-10oC to 40oC 

Max Charging Power 

100W 

App I Live View 

MobileApp 

DJI Pilot 

EIRP 

100mW 

Live View Working Frequency 

2.4GHz ISM 

Live View Quality 

720P @ 30fps (depending on conditions and mobile device) 

Latency 

220ms (depending on conditions and mobile device) 

Required Operating Systems 

iOS 8.0 or later 

Android 4.1.2 or later 

Recommended Devices 

iOS: iPhone Ss, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi +Cellular, iPad mini 2, iPad mini 2 Wi-Fi 

+ Cellular, iPad Air 2, iPad Air 2 Wi-Fi +Cellular, iPad mini 3, and iPad mini 3 Wi-Fi +Cellular. This app is 

optimized for iPhone Ss, iPhone 6, and iPhone 6 Plus 

Android: Samsung 55, Note 3, Sony Xperia Z3, Google Nexus 711, Google Nexus 9, Mi 3, Nubia Z7 mini 

*Support for additional Android devices available as testing and development continues 

22 
Main Controller: 

Processing and analyzing flight data in real time takes serious power. The Main 

Controller is the control center of your Phantom 3. It collects data from the entire 

system, including motor speed, GPS location, your command inputs, and data from 

automatic sensors, and analyzes it all to tell your Phantom 3 exactly how to behave at 

any given moment. 

GPS: 

Never lose track of your Phantom 3. GPS and GLONASS combine to make the Phantom 

3 completely aware of its location and relation to you. It hovers more precisely, moves 

more accurately, and locks onto satellites faster. With the new availability of GLONASS, 

a minimum of 36 satellites are available to you around the world at any time. 

Through the DJI Pilot app, you can track its location on a live map, and record your 

takeoff point so you can bring it back to you with the tap of a finger. 

IMU: 

Keeping your Phantom 3 stable and flying the way you want it to is the Inertial 

Measurement Unit. Inside is a 6-axis gyroscope and an accelerometer that records and 

relays even the smallest changes in tilt and movement. It is constantly at work, 

detecting the slightest changes and compensating for them automatically. 

ESCs 

Motor speed is critical to flight, and each motor is managed individually by the 

Electronic Speed Controllers. ESCs not only relay vital motor speed information to the 

Main Controller, they also send commands back to the motors based on your input. 

This constant communication keeps your Phantom stable in flight, and also helps you 

achieve any flight movement, from gentle pans to rapid acceleration. 

23 
following specific operating limitations: 

As much as is possible, the applicant attempts to have a redundancy in expertise 

and skill sets related to operationsoftheUASs. 

Pilot in Command (PIC) 

• Pilotingthe UAS. Thiswilllnclude: 

Takeoff 

Normal flight 

Flight during 

emergency 

procedures 

Landing 

• Assembling the UAS 

• Performs pre-flightchecksofthefirmware • Performs pre-flight checks of the hardware 

• Performs preflight checks of the software 

Spotter 

• Relays notable flight parameters such as h:ileystrength, 

and metricsian the UAS. 

• Primary communication between pilot and on-site safety 

personnel 

• Will hold physical documents related to current flight 

• Performs pre-flight checks oft he data collection equipment 

• Monitors ground and greater above-ground environmentforsafety 

concerns 

Technician 

• Assembling the UAS 

Preforms pre-flight checks of the hardware 

• Preforms pre-flightchecksofthesoftware 

24 
A. Before power is applied 

• Check for physical damage and any missing hardware 

• Check all electronics present and connected/ check cord connections are tight. 

• Confirm all batteries are charged 

• Check all rotors and moving parts for debristhat would prevent proper 

operation 

• Check weather patterns the night beforehand. 

• Check all data collection equipmentfor proper nstallation/operation 

• Checkalldatacollectionequipmentforissuesthat would impact safe 

operations offlight package. 

B. After Power Source Applied 

- Confirm proper power reading of battery 

• Run hardware based systems check 

Run software based systems check 

• Check flight LED array 

• Confirm proper radio link to flight controller 

• Confirm proper radio link to data collection device controller 

• Confirm secondary controller connection to UAS on board flight controller 

• Confirm waypoints and geofences are accurate to current flight 

• Confirm desired behavior of emergency fail safes 

• Check with on site safety personnel for any changes in goals/flight path 

IV. Flight-time Checklist 

• Check with on-site personnel for safe flight area for first flight 

• Record relevant metrics inflightlog 

• Check for ground hazards at home-base and rectify 

Confirm more than eight (8) satellite GPS lock 

• Confirm Initial state of controllers 

Initialize rotors and check for proper operation 

Perform controlled flight to hover mode approximately five (5) 

25 
maximumfive (5) meter distance to PI Cand returnto Initial position 

• Return UAS to normal orientation 

Perform controlled flight to hover mode one (1) meter above the 

ground 

• Check landing gear landing mode (down) operation 

• Land the UASandcheckfor proper de-initialization of rotors 

Perform controlled flight to hover mode approximatelyfive (5) meters above 

the ground 

• Check landinggear flight mode (up) operation 

• Operate UA5 to each waypoint/position until maximum flight time is 

achieved 

Return UASto normal orientation 

• Perform controlled flight to hover mode approximately one (1) meter above 

the ground 

• Check landinggear landing mode (down) operation 

• Land the UASand check for proper de-initialization of rotors 

• Remove power to the flight package 

• Remove power to the data collection package 

• Remove power to controllers 

• Complete flight log 

V. Standing Procedures 

• The Pilot, Spotter, and Technician will be the only members inthe forward 

frghtarea. On-site 

personnel will be within verbal range behind the PIC, Spotter, and Technician 

• The maximum power used to control the device is soft limited to 75% in 

order to maintain power iri reserve for unforeseen conditions 

• Flighttime is limited to l5 minutes and goa Is will be planned in phases 

to be accomplished during this time 

• Flight time is limited to reserving 25% battery power 

• Flight height is soft limited to visible and unaided line of sight (VLOS) 1 and 

hard limited to 400ft. 

AGL 

• Flighttime is limited to operation in safe environmental conditions 

26 
o Note:AII irregular behavior have root cause analysis performed 

before UASoperation 6resumed 

VI. Emergency procedures 

Loss of Remote Signal 

o The flight package features an optional enhanced fail-safe which 

returnsthe UAStothe home basewaypointviathesame path 

taken to point of lost signal 

o The UAS will then perform a hover overthis waypoint and then 

perform a controlled landing 

• LossofGPSsignal 

o The system will operate in GPS mode with three (3) satellites 

o At brofthree (3)GPSsatellites, manual mode can be activated ofthe 

flight package can be programmed to perform a controlled landing 

to the home base waypoint. 

o Ground based height ranging is performed by separate system and so 

loss of GPS will 

not impact controlled landing n a safe manner 

Loss of Ground Control Software 

o This will not affect operation of the flight. The unit will be piloted to 

a safe landing area then landed so that examination of the link 

can be made. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety. 

GSI submits that an equivalent level of safety established by Section 61.113(a) and 

(b) will be maintained because no PIC will be allowed to operate the DJI PHANTOM 3 UAS 

unless that PIC has demonstrated, through the DJI PHANTOM 3 UAS training, that the PIC is 

able to safely operate the DJI PHANTOM 3 UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

27 
to safely operate the DJI PHANTOM 3 UAS, GSI submits that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship skills 

necessary for GSI's specific proposed flight operations. 

As in Exemption No. 11109, GSI will not allow any PIC to operate the DJI PHANTOM 3 

UAS unless that PIC has demonstrated through the DJI PHANTOM 3 UAS training requirements 

that the PIC is able to safely operate the DJI PHANTOM 3 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

28 
for flight based upon the DJI PHANTOM 3 UAS

s compliance with its operating documents and 

as stated in the conditions and limitations herein. 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude ofthe DJI PHANTOM 3 UAwill be reported to air traffic control (ATC) in feet above 

ground level (AGL), and GSI will operate the DJI PHANTOM 3 UA within visual line of sight, at 

or below 400 feet AGL. Prior to each flight, a zero altitude initiation point is established at 

ground level. 

29 
91.151(a)(l), 91.405(a), 91.407(a)(l), 91.409{a)(l) & (a)(2), And 91.417(a) & 

(b) Would Not Adversely Affect Safety. 

In seeking this exemption, GSI submits that the level of safety with regard to the regulatory 

maintenance and alteration requirements established 

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b) will be met because 

GSI, will use its trained technicians to perform maintenance, alterations, or preventive 

maintenance on the unmanned aircraft system using the methods, techniques, and practices 

prescribed in the manufacturer's maintenance manual. Furthermore, GSI will document and 

maintain all maintenance records for the DJI PHANTOM 3 UAS. 

The Applicant contends that operation of its UASs will not ·"create a hazard to users of the 

national airspace system or the public." As stated in ll2 P.L 95 § 333(b). Given the diminutive 

size and weight of the UASs, combined with their operation in rordoned off and well-controlled 

areas. The applicant's UASs falls within congress's contemplated safety zone. The applicant's 

UASs have an established safety record bolstered by multi-point preflight checklists, 

awareness of their surroundings and intimate knowledge and behavior ofthe UASs platform In 

many weather conditions. This safety record and implemented operational practices 

demonstrates an awareness of public safety. 

The Applicant's operations routinely provide a level of safety at least equal to existing rules 

and in nearly every instance, exceeds existing rules. 

The applicant's UASs does not and cannot operate on or near airports and generally has only 

operated its fleet on private grounds with cordoned off areas or areas under the control of the 

property owner/ client with assistance by safety officials employed by the business. The applicant 

determines the areas needed to fulfill the clients goals and only operates its UASs ilthese flight 

zones and only in compliance with well-regarded safety protocols set forth initially by the RC UAS 

trade and hobby groups and recently codified by relevant FARs. 

The applicant is standartiza:irnthefollowing practices to ensure safe operations of its UASs safe; 

Work with on-site personnel to plan the flight goals. 

Work with on-site personnel to restrict access to non-essential persons. 

30 
Numerous pre-programmed fail-safes that ensure specific behavior per issue. 

Three main roles supplemented by on-site safety personnel. 

Employ controlled lifecycle management of components to guard against failures. 

Preform a site check day(s) before flight to identify potential issues. 

Subscribe to relevant local and safety alerts 

Expertly choose data collection instruments and accessories to minimize flight requirements or 

expertise. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012- size, weight, 

speed, operating capabilities, proximitytoairportsand populated areasandoperationwithinvisual 

line of site and national security- provide more than adequate justification for the grant of the 

requested exemptionsallowingcommercial operationoftheapplicant's UASs in conducting aerial 

acquisitions and research for geotechnical hazards. 

6. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, GSI requests that the FAA prescribe 

special conditions for the intended operation of the DJI Phantom 3, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R. §§ 91.151(a)(1), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit 

31 
airworthiness certification in accordance with any requirements that must be established for 

the safe operation of the aircraft systems in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

§ 21.16, for operation of the OJI Phantom 3, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate 

or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel 

or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards for the aircraft, 

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent 

to that established in the regulations. 

32 
safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R. Sections 

61.113(a) 

& (b), 91.7(a), 91.121, 91.151(a)(1), 91.40S(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 

91.417(a) & (b). 

E. A Summary That Can Be Published In The Federal Register, stating: 

The Rules From Which GSI Seeks Exemption: 

GSI seeks exemption from the requirements of 14 C.F.R. Sections 61.113{a) & (b), 

91.7(a), 91.121, 91.151{a}(1}, 91.405{a), 91.407(a}(1}, 91.409(a)(1} & (a)(2}, and 

91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption GSI Seeks: 

This exemption will permit GSI to commercially operate an Unmanned Aircraft System 

(UAS} for the purpose of conducting aerial acquisitions and research within the National 

Airspace System (NAS}. 

F. Any Additional Information, Views, Or Arguments Available To Support 

GSI's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, GSI's request for exemption may be granted pursuant 

to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

33 
CONCLUSION 

As set forth herein, GeoStabilization International, LLC seeks an exemption pursuant to 

14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the DJI PHANTOM 3 UAS commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial acquisitions within the 

National Airspace System (NAS). 

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of 

the FAA Modernization and Reform Act of 2012, while also advancing the interests of the 

public, by allowing GSI to safely, efficiently, and economically operate the DJI PHANTOM 3 UAS 

commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, GSI respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R. Sections 

61.113{a) & (b), 91.7(a), 91.121, 91.151{a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),and 

91.417(a) & (b), and permit GSI to operate the DJI PHANTOM 3 UAS for the purpose of 

conducting aerial acquisitions and research within the NAS. 

34 
35 

543 31 Rd 

Grand Junction, CO 81504 

Tel: (970) 210-6170 

Fax: (970) 245-7737