# July 30 , 2015

Exemption No. 12243 Regulatory Docket No. FAA

– 20 15

– 2032

M s

. Michelle Urlacher GeoStabilization International, LLC 543 31 R oa d Grand Junction, CO 81504

Dear M s

. 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 petitione r or operator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct aerial acquisitions and research

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

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

. Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3

. In accordance with the statutory criteria provided in Section 333 of P ublic 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

# 2

fi nds that relief from 14 CFR part 21 , C ertification 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 1



# . 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 s

. 11062 to Astraeus Aerial ( see Docket No . FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmann ed 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 petiti oner 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 (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.

# 3

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 Ph antom 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 o perated 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 maint ains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;
e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation fo r 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 thi s 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 limita tions in this exemption and the procedures outlined in the operating documents,

# 4

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 ope rator 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 up dated 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 FA A’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 op eration 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 mu st 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 com ponents, 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 Col u mbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certif icate.

# 5

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 ( traini ng, 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 op erations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropri ate 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 visu al 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 symbo l 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 sign al, the UA must return to a pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is proh ibited 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 cond ucted 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

.

# 6

22. All aircraft operated in accordance with this exemption must be identified by serial
num ber, 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 enforcem ent 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 tha t 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 nonparticipa ting 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 control led

- access property with permission from the prop erty 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 vert ical boundaries of the operational area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions containe d on the NTSB Web site: www.ntsb.gov

.

# 7

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 a rea 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 f

or 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 th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to b e 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 , unle ss sooner superseded or rescinded.
Sincerely, / s/ John S. Duncan Director, Flight Standards Service

EnclosuresUNITED STATES

OF AMERICA DEPARTMENT

OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON,

DC Regulatory Docket

**No. ~-----**  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) 245-7737TABLE
OF CONTENTS

Page GLOSSARY

OF ABBREVIATIONS ............................................................................................

3 SUMMARY ............................................................................................................................

4 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 2AGL AOI ATC ATO AV C.F.R. COA FAA FAR GCS NAS NOT AM PIC Section 333 SOP UA UAS VFR VLOS VMC vo
GLOSSARY

OF ABBREVIATIONS Above Ground Level Area of Interest Air Traffic Control 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

3SUMMARY GeoStabilization International,

LLC. seeks exemption from the requirements

of 14 C.F.R.
§§ 61.113(a)

& (bL 91.7(aL 91.121, 91.151(a)(1), 91.405(aL 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a)

& (bL to operate

an Unmanned Aircraft System pursuant

to Section 333 ofthe FAA 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 4unmanned aircraft (UA) and

a remote controller.

The DJI PHANTOM

3 UA has

a maximum

net weight

of approximately 1,280g, while having

a diagonal
size (including propellers)

590 mm. The DJI PHANTOM

3 UA

is equipped with four propellers driven

by
a 6000 mAh LiPo 25 battery. The DJI PHANTOM

3 UA that will be operated

by GeoStabilization International,

LLC will 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, 5Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions
the Administrator

to operate the DJI PHANTOM

3 UAS within the National Airspace System (NAS), and for an exemption from the requirements

of 14 C.F.R.
§§ 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). 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 6the ground. GSI seeks relief from Section
91. 7(a), entitled Civil aircraft airworthiness, because
the DJI PHANTOM

3 UAS does not require

an airworthiness certificate

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

H. As such, GSI submits that

it will ensure that the DJI PHANTOM

3 UAS

is in an 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

s afe 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 7Email:Michelle@gsi.usTHESPECIFICSECTIONSOF14C.F.RFROMWHICHGEOSTABILIZATIONINTERNATIONAL,LLCSEEKSEXEMPTION1.GSISeeksExemptionFromTheRequirementsOfSection61.113(a)And(b).Section61.113,entitledPrivatepilotprivilegesandlimitations:Pilotincommand,subsections(a)and(b)prescribethefollowing,inpart:(a)Nopersonwhoholdsaprivatepilotcertificatemayactasapilotincommand(PIC)ofanaircraftthatiscarryingpassengersorpropertyforcompensationorhire;normaythatperson,forcompensationorhire,actasPICofanaircraft.(b)Aprivatepilotmay,forcompensationorhire,actasPICofanaircraftinconnectionwithanybusinessoremploymentif-(1)Theflightisonlyincidentaltothatbusinessoremployment;and(2)Theaircraftdoesnotcarrypassengersorpropertyforcompensationorhire.2.GSISeeksExemptionFromTheRequirementsOfSection91.7(a).Section91.7,entitledCivilaircraftairworthiness,subsection(a),statesthefollowing:(a)Nopersonmayoperateacivilaircraftunlessitisinanairworthycondition.3.GSISeeksExemptionFromTheRequirementsOfSection91.121.Section91.121,entitledAltimetersettings,subsection(a),statesthefollowing,inrelevantpart:(a)Eachpersonoperatinganaircraftshallmaintainthecruisingaltitudeorflightlevelofthataircraft,asthecasemaybe,byreferencetoanaltimeterthatisset,whenoperating--(1)Below18,000feetMSL,to--(i)Thecurrentreportedaltimetersettingofastationalongtherouteandwithin100nauticalmilesoftheaircraft;(ii)Ifthereisnostationwithintheareaprescribedinparagraph(a)(1)(i)ofthissection,thecurrentreportedaltimetersettingofanappropriateavailablestation;or8(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; 4.
GSJ Seeks Exemption From The Requirements

Of Section 91.151(a)(1). Section 91.151, entitled Fuel requirements

for flight

in VFR conditions, subsection (a)(1), 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
unle ss-- (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 9unless, within the preceding

12 calendar months,

it has had; (1)
An annual inspection

in accordance
with part 43 ofthis 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. 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 10the last inspection required

by the inspection program under which the aircraft and its appliances

are maintained. (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)(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. 11Assetforthmorefullybelow,GSIsubmitsthatanequivalentlevelofsafetywillbemaintainedbecausenoPICwillbeallowedtooperatetheDJIPHANTOM3UASunlessthatPIChasdemonstrated,throughtheDJIPHANTOM3UAStrainingrequirements,thatthePICisabletosafelyoperatetheDJIPHANTOM3UASinamannerconsistentwiththeoperationsspecificationsasdescribedinthisexemption,includingevasiveandemergencymaneuvers,aswellasmaintainingappropriatedistancesfrompeople,vessels,vehiclesandstructures.Further,GSIsubmitsthatallflightsoftheDJIPHANTOM3UAS,conductedbythePICpursuanttothegrantofthisPetitionwillbe:(1)incidentaltoGSI'sbusiness;and(2)notcarrypassengersorpropertyforcompensationorhire.2.ExtentofReliefGSISeeksAndTheReasonGSISeeksReliefFromSection91.7(a).RelieffromSection91.7(a),entitledCivilaircraftairworthiness,isrequestedtotheextentrequiredtoallowGSItodeterminethattheDJIPHANTOM3UASisinanairworthyconditionpriortoeveryflightbyensuringthattheUASisincompliancewiththeDJIPHANTOM3UASOperatorManualandthattheUASisinconditionforsafeflight.Copiesofthemanuals,whichcontainproprietaryinformation,areattachedheretoasExhibitsA.respectively,andaretobeheldinaseparatefilepursuantto14C.F.R.§11.35(b).GSIseekstherequestedreliefbecausetheDJIPHANTOM3UASdoesnotrequireanairworthinesscertificateinaccordancewith14C.F.R.Part21,SubpartH.Therefore,GSIwillensurethattheDJIPHANTOM3UASisinanairworthyconditionbaseduponitscompliancewiththeoperatingdocumentspriortoeveryflight,andasstatedintheconditionsandlimitationsbelow.3.ExtentOfReliefGSISeeksAndTheReasonGSISeeksReliefFromSections1291.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a)

& (b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l)

& (a)(2), and 91.417(a)

& (b) only apply
to aircraft with an airworthiness certificate,

GSI requests relief from these Sections because
the DJI PHANTOM

3 UAS does not require

an airworthiness certificate.

As set forth more 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 13and gas industries.

The DJI PHANTOM

3 UAS will provide safe, efficient,
and economical aerial acquisition

and research operations

to further identify geotechnical hazards

of which are critical to the well-being

of the general public. The specific operations
that GSI will perform with the DJI PHANTOM

3 UAS demonstrate 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.

14ConductingaerialacquisitionswiththeDJIPHANTOM3UAS,insteadofmannedaircraft,willgreatlybenefitthepublicbydrasticallyreducingthelevelsofairandnoisepollutiongeneratedduringtraditionalaerialsurveyflightoperations.Byusingbatterypowerandanelectricmotor,theDJIPHANTOM3UASproducesnoairpollution,andisthemostviableenvironmentallyconsciousalternativetothecabinclass,sixcylinderinternalcombustiontwinengineaircraftthataretypicallyutilizedforaerialacquisitions,whileburningapproximately20-30gallonsperhourofleadedaviationfuel.TheDJIPHANTOM3UA,whilereducingthecarbonfootprintofaerialacquisitions,alsoeliminatesnoisepollution,asitsbatterypoweredelectricmotorisbarelyaudibleduringthetake-offphase,andcannotbeheardwhenoperatingmorethan100feetabovegroundlevel.ByusingtheDJIPHANTOM3UAStoperformaerialacquisitions,thesubstantialrisktolifeandpropertyintheairandontheground,whichisusuallyassociatedwithtraditionalmannedaircraftflightoperations,willbesubstantiallyreducedorcompletelyeliminated.Asidefromthelackofaircrewmemberslocatedonboardtheaircraft,theDJIPHANTOM3UA(weighingapproximately1,280gatitsmaximumgrossweightwithaDiagonalSize590mm,withnofuelonboard),haslessphysicalpotentialforcollateraldamagetolifeandpropertyontheground,andintheair,comparedtothemannedaircraftthattypicallyconductaerialacquisitions(weighingapproximately6,500poundswithawingspanofapproximately40feet,alengthof34feet,andafuelcapacityof180gallons).Furthermore,byusingtheDJIPHANTOM3UAStoperformaerialacquisitionsofpotentialgeotechnicalriskstothepublicweareabletoquickly,andefficientlyaccessemergencysituationsanddevelopadesign-buildapproachtoremedysuchgeohazardrisks.154. Performing Aerial Acquisition Operations With The DJI PHANTOM

3 UAS Will Benefit The Economy. In addition

to being safe and efficient,
the DJI PHANTOM

3 UAS

is also an economical alternative

to using manned aircraft

to conduct aerial acquisitions.

As such, operation

of the DJI PHANTOM

3 UAS will allow United States based companies,

like GSI, to remain competitive 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.

16Specifically,

the DJI PHANTOM

3 UAS will be operated

in accordance
with operating limitations set forth herein and the Federal Aviation Regulations, including
the minimum altitude requirements

of 14 C.F.R.

§ 91.119. D. 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 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(2))whetheracertificateofwaiver,certificateofauthorization,orairworthinesscertificationundersection44704oftitle49,UnitedStatesCode,isrequiredfortheoperationofunmannedaircraftsystemsidentifiedunderparagraph{1).(c)RequirementsforSafeOperation.--JftheSecretarydeterminesunderthissectionthatcertainunmannedaircraftsystemsmayoperatesafelyinthenationalairspacesystem,theSecretaryshallestablishrequirementsforthesafeoperationofsuchaircraftsystemsinthenationalairspacesystem.Inseekingthisexemption,GSIsubmitsthattheDJIPHANTOM3UAScanoperatesafelyintheNASpursuanttoFMRASection333,asdemonstratedby:(a)thesafeoperationalhistoryandcurrentuseoftheDJIPHANTOM3UASintheNAS;(b)thecharacteristicsoftheDJIPHANTOM3UAS;(c)theprivatepilotcertificationrequirement;and(d)thespecificoperatinglimitations.a.TheOJIPHANTOM3UASHasAProvenHistoryOfOperationInTheNAS.TheDJIPhantom3utilizesfour(4)counter-rotatingpropellerspairedoppositelytoeachotherforbalance,controlandstability.ThetotalspanoftheUAS6590mmincludingpropellers,allowingforstableflightorlandingevenwiththesuddenonsetofdetrimentalenvironmentalconditions.TheUASsmaximumweight(includingbattery,propellers)of13Kg.Theapplicant'sUASisdesignedtohoverinplacetocapturephotographicdataandthenoperateatlessthan50knotmaximumspeedtothenextpointofInterest.Theyarecapableofverticalandhorizontaloperationsbut,inpractice,isoperatedonlywithinunaidedVLOSofthePIC.InadditiontothePIC,theApplicantemploysaspotter(VOSrole)andatechnician(secondaryVOSandonsitepersonnelliaison)whicharewithinverbalcommunicationrange.IntheeventoflossofvisualoftheUASthePJCcanchangetheflightcontrolsfromCartesian(X,Y,Z.)basedcontrolstoradial(r,a,h)basedcontrolswhichallowsthePICtoutilizeonecontrolleraxistorecalltheUAStothePIC'spositionwithoutconcerntothecurrentheadingoftheUASs.TheUASsalsohaveaReturn-to-HomefeaturethatwillallowtheUAStoreturntothePIC'slocationinthecaseoftheUASbsingsignaltothePIC,orfthePICinitiatestheReturn-toHomeprocedure.IntheeventoflossofsightoftheUASsintoanareacontaininghazardsorpossiblehazards,thespotterhasaheads-up-displaycontainingalivevideofeedwhichcanbeusedtolocatetheUASwhileitmaintainsitspositionhovermode.TheUAShasdemonstrateditsabilitytomaintainitspositionbyGPS,SONAR,andOpticalflowcamerawithanaccuracyof+/-lOcmverticaland+1-1mhorizontal.Alloftheapplicant'sUAS'sutilizeLiPo(lithiumpolymer)batterybasedpowersources,decreasingsafetyrisksfrommoreeasilycombustible,fuelbased,powersources.Flighttimesgenerallylastbetween18eight (8) to ten {10} minutes allowingthe
staff to work with small areas per phase. The maximum flight time without payload

is approximately

25 minutes; however practical safe operation limits this to l5 minutes

to gve ample time
to control the UASs
to
a safe landing zone. The applicant further restricts flight time by to operating the UASs with less than twenty five percent (25%) battery capacity. 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 19ISORange100-3200(video)100-1600(photo)ShutterSpeed8s-1/8000sImageMaxSize4000X3000StillPhotographyModesSingleShotBurstShooting:3/5/7shotsAutoExposureBracketing(AEB):3/5BracketedFramesat0.7EVBiasTime-lapseVideoRecordingModesPhantom3ProfessionalUHD:4096x2160p24/25,3840x2160p24/25/30FHD:1920x1080p24/25/30/48/50/60HD:1280x720p24/25/30/48/50/60Phantom3AdvancedFHD:1920x1080p24/25/30/48/50/60HD:1280x720p24/25/30/48/50/60SupportedSDCardTypesMicroSDMaxcapacity:64GB.Class10orUHS-1ratingrequiredMaxBitrateOfVideoStoragePhantom3Professional60MbpsPhantom3Advanced40MbpsSupportedFileFormatsFAT32/exFATPhoto:JPEG,DNGVideo:MP4,MOV(MPEG-4AVC/H.264)OperatingTemperatureoocto40°CGimbalControllableRangePitch-90°to+30°Stabilization3-axis(pitch,roll,yaw)20VisionPositioningMaxVelocityLessthan8m/s(when2 maboveground)AltitudeRange30cm-300cmOperatingRange30cm-300emOperatingEnvironmentSurfacewithclearpatternandadequatelighting(Lux>15)RemoteControllerOperatingFrequency2.400GHz-2.483GHzMaxDistance2000m(outdoorsandunobstructed)VideoOutputPortUSBOperatingTemperature0°C-40°CBattery6000mAhLiPo2SMobileDeviceHolderFortabletorphoneReceiverSensitivity(1%PER)-101dBm±2dBmTransmitterPower(EIRP)FCC:20dBmCE:16dBmWorkingVoltage1.2A@7.4VBatteryChargerVoltage17.4vRatedPowerPhantom3Professional100WPhantom3Advanced57WIntelligentFlightBatteryCapacity4480mAh21Voltage 15.2



## v Battery Type LiPo 4S Energy 68Wh Net Weight 365

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 

### 22Phantom

3 Flight System: Maintaining complete control and stability

in the air
is crucial

to every successful flight. The Phantom

3 contains
the best and newest

OJI flight technology, giving you an enjoyable experience through full, automatic intelligent support. These systems help you fly better and safer, and are designed

so that you never have to think about them at all. 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. 23c.FlightsWillBeConductedPursuantToSpecificOperatingLimitations.Inseekingthisexemption,GSIproposestocommerciallyoperatetheDJIPHANTOM3forthespecialpurposeofconductingaerialacquisitionswithintheNAS,pursuanttothefollowingspecificoperatinglimitations:Asmuchasispossible,theapplicantattemptstohavearedundancyinexpertiseandskillsetsrelatedtooperationsoftheUASs.PilotinCommand(PIC)•PilotingtheUAS.Thiswilllnclude:TakeoffNormalflightFlightduringemergencyproceduresLanding•AssemblingtheUAS•Performspre-flightchecksofthefirmware•Performspre-flightchecksofthehardware•PerformspreflightchecksofthesoftwareSpotter•Relaysnotableflightparameterssuchash:ileystrength,andmetricsiantheUAS.•Primarycommunicationbetweenpilotandon-sitesafetypersonnel•Willholdphysicaldocumentsrelatedtocurrentflight•Performspre-flightchecksofthedatacollectionequipment•Monitorsgroundandgreaterabove-groundenvironmentforsafetyconcernsTechnician•AssemblingtheUASPreformspre-flightchecksofthehardware•Preformspre-flightchecksofthesoftware24• Secondary Communication

link between pilot and on-site safety personnel • Relays
to the spotter and records notable flight parameters metrics from the UAS Monitors ground and greater above-ground environment

for safety concerns Ill. Pre-Flight Checklist 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) 25metersabovetheground•Checklandinggearflightmode(up)operation•Performcontrolledmulti-axisrollproceduretocheckforproperorchestratedrotoroperation•Performcontrolledmulti-axis(ifapplicable)controlprocedureofdatacollectionpackage•Switchcontrollermodetoradialbased,checkforproperoperationtomaximumfive(5)meterdistancetoPICandreturntoInitialposition•ReturnUAStonormalorientationPerformcontrolledflighttohovermodeone(1)meterabovetheground•Checklandinggearlandingmode(down)operation•LandtheUASandcheckforproperde-initializationofrotorsPerformcontrolledflighttohovermodeapproximatelyfive(5)metersabovetheground•Checklandinggearflightmode(up)operation•OperateUA5toeachwaypoint/positionuntilmaximumflighttimeisachievedReturnUAStonormalorientation•Performcontrolledflighttohovermodeapproximatelyone(1)meterabovetheground•Checklandinggearlandingmode(down)operation•LandtheUASandcheckforproperde-initializationofrotors•Removepowertotheflightpackage•Removepowertothedatacollectionpackage•Removepowertocontrollers•CompleteflightlogV.StandingProcedures•ThePilot,Spotter,andTechnicianwillbetheonlymembersintheforwardfrghtarea.On-sitepersonnelwillbewithinverbalrangebehindthePIC,Spotter,andTechnician•Themaximumpowerusedtocontrolthedeviceissoftlimitedto75%inordertomaintainpoweririreserveforunforeseenconditions•Flighttimeislimitedtol5minutesandgoaIswillbeplannedinphasestobeaccomplishedduringthistime•Flighttimeislimitedtoreserving25%batterypower•Flightheightissoftlimitedtovisibleandunaidedlineofsight(VLOS)1andhardlimitedto400ft.AGL•Flighttimeislimitedtooperationinsafeenvironmentalconditions26• Flight staff will maintain proximity

so as to be in !Ear verbal range • The PICwill announce

all movements

to staff and on-site staff so that non-PIC staff members

can identify possible safety concerns before operation ofthe UAStothe nextwaypointor position • All regular and irregularoperationsare notedwithtimestamps, relevant UAS metrics and corrective action procedures {CAP) that are performed

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 27people, vessels, vehicles
and structures. Considering
GSI's proposed area of operations

and the operating limitations

set forthabove; the parallel nature

of private pilot aeronautical knowledge requirements

to those

of commercial
pilot requirements

(See Exemption

No. 11062); and the airmanship
skills necessary 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.

283.ReasonsWhyAnExemptionFromTheRequirementsOfSection91.7{a)WouldNotAdverselyAffectSafety.ThelevelofsafetyestablishedbySection91.7(a)willbemaintainedbecausepriortoeveryflight,GSIwillensurethattheDJIPHANTOM3UASisinanairworthyconditionandsafeforflightbasedupontheDJIPHANTOM3UAS'scompliancewithitsoperatingdocumentsandasstatedintheconditionsandlimitationsherein.4.ReasonsWhyAnExemptionFromTheRequirementsOfSection91.121WouldNotAdverselyAffectSafety.TheequivalentlevelofsafetyestablishedbySection91.121willbemaintainedbecausethealtitudeoftheDJIPHANTOM3UAwillbereportedtoairtrafficcontrol(ATC)infeetabovegroundlevel(AGL),andGSIwilloperatetheDJIPHANTOM3UAwithinvisuallineofsight,atorbelow400feetAGL.Priortoeachflight,azeroaltitudeinitiationpointisestablishedatgroundlevel.29The FAA has previously granted relief from Section 91.121 specific

to UAS,

in circumstances similar,

in all material respects,

to those presented herein. 5. Reasons Why An Exemption From The Requirements

Of Sections 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 area

s 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. 30OperationsbyunaidedVLOSoperationsonly.Operationphasesofl5minutesinlength.Operationtominimal25%batterypower.OperationofdevicetoGPSaidedreadoutofnomorethan400feetAGL.Numerouspre-programmedfail-safesthatensurespecificbehaviorperissue.Threemainrolessupplementedbyon-sitesafetypersonnel.Employcontrolledlifecyclemanagementofcomponentstoguardagainstfailures.Preformasitecheckday(s)beforeflighttoidentifypotentialissues.SubscribetorelevantlocalandsafetyalertsExpertlychoosedatacollectioninstrumentsandaccessoriestominimizeflightrequirementsorexpertise.SatisfactionofthecriteriaprovidedinSection333oftheReformActof2012-size,weight,speed,operatingcapabilities,proximitytoairportsandpopulatedareasandoperationwithinvisuallineofsiteandnationalsecurity-providemorethanadequatejustificationforthegrantoftherequestedexemptionsallowingcommercialoperationoftheapplicant'sUASsinconductingaerialacquisitionsandresearchforgeotechnicalhazards.6.TheFAAMayPrescribeAnyOtherConditionsForSafeOperation.InaccordancewithSection333oftheFAAModernizationandReformActof2012(FMRA)and14C.F.R.§21.16entitledSpecialConditions,GSIrequeststhattheFAAprescribespecialconditionsfortheintendedoperationoftheDJIPhantom3,whichcontainsuchsafetystandardsthattheAdministratorfindsnecessarytoestablishalevelofsafetyequivalenttothatestablishedby14C.F.R.Part21,SubpartH,and14C.F.R.§§91.151(a)(1),91.405(a),91.407(a)(1),91.409(a)(1)&(a)(2),and91.417(a)&(b).Suchspecialconditionswillpermit31safeoperationoftheunmannedaircraftforthelimitedpurposeofconductingaerialacquisitionswithintheNAS.FMRASection333setsforththerequirementsforconsideringwhetheraUASwillcreateahazardtousersoftheNASorthepublic,orotherwiseposeathreattonationalsecurity;andfurther,providestheauthorityforsuchUAStooperatewithoutairworthinesscertificationinaccordancewithanyrequirementsthatmustbeestablishedforthesafeoperationoftheaircraftsystemsintheNAS.Likewise,theAdministratormayprescribespecialconditionspursuantto14C.F.R.§21.16,foroperationoftheOJIPhantom3,sincetheairworthinessregulationsof14C.F.R.Part21donotcontainadequateorappropriatesafetystandards,duetothenovelorunusualdesignfeaturesoftheaircraft.Section21.16,entitledSpecialConditions,statesthefollowing:IftheFAAfindsthattheairworthinessregulationsofthissubchapterdonotcontainadequateorappropriatesafetystandardsforanaircraft,aircraftengine,orpropellerbecauseofanovelorunusualdesignfeatureoftheaircraft,aircraftengineorpropeller,heprescribesspecialconditionsandamendmentstheretofortheproduct.ThespecialconditionsareissuedinaccordancewithPart11ofthischapterandcontainsuchsafetystandardsfortheaircraft,aircraftengineorpropellerastheFAAfindsnecessarytoestablishalevelofsafetyequivalenttothatestablishedintheregulations.32See 14 C.F.R.

§ 21.16. Therefore,

in accordance
with FMRA Section 333 and 14 C.F.R.

§ 21.16, the FAA may prescribe special conditions

for GSI's intended operation ofthe
DJI PHANTOM

3 UAS, 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. 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 33further, provides
the authority

for such UAS to operate without airworthiness certification. As discussed

in detail above, the DJI PHANTOM

3 UAS has
in the past, and will continue in the future,

to operate safely

in the NAS without creating

a hazard

to users
of the NAS, or the public,

or otherwise pose

a threat

to national security. 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. 34Dated: May 18, 2015

35 Respectfully submitted, GeoStabilization International,

LLC **~** Michelle Urlacher 543 31 Rd Grand Junction,

CO 81504 Tel: (970) 210-6170 Fax: (970) 245-7737