Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 1 

### UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION

ADMINISTRATION WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:



# GEOVIRONMENT CONSULTING

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(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), AND 91.417(a) & (b) CONCERNING

COMMERCIAL OPERATION OF 3D ROBOTICS SOLO UNMANNED AIRCRAFT SYSTEM TO SECTION

333 OF FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on Nov 25, 2015

G e ovironment Consulting

630 W 7 th Street

San Jacinto, CA 92583

951

- 791

- 9600



### aminor@geovironmentconsulting.comGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 2



# Table of Contents

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................................ ................................ ..... 3

SUMMARY

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

................................ ................................ ................... 5

BACKGROUND

................................ ................................ ................................ ................................ ................................ ........ 6

BASIS FOR PETITION

................................ ................................ ................................ ................................ ........................... 7

Name and Address of Petitioner

................................ ................................ ................................ ................................ ..... 9

A. Name And Address Of The Petitioner

................................ ................................ ................................ ......... 9

B. The Specific Sections Of 14 C.F.R. From Which Geovironment Consulting seeks

Exemption

................................ ................................ ................................ ................................ ................................ .......... 9

1. Geovironment Consulting Seeks Exemption From The Requirements Of Section

61.113(a) And (b).

................................ ................................ ................................ ................................ .......................... 9

2. Geovironment Consulting Seeks Exemption From The Requirements Of Section 91.7(a).

9

3. Geovironment Consulting Seeks Exemption From The Requirements Of Section 91.121. 9

4. Geovironment Consulting Seeks Exemption From The Requirements Of Section

91.151(b).

................................ ................................ ................................ ................................ ................................ ........ 10

5. Geovironment Consulting Seeks Exemption From The Requ irements Of Section 91.405

(a). 10

6. Geovironment Consulting Seeks Exemption From The Requirements Of Section

91.407(a)(1)

................................ ................................ ................................ ................................ ................................ ... 10

7. Geovironment Consulting Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

................................ ................................ ................................ ............................ 10

8. Geovironment Consulting Seeks Exemption From The Requirements Of Sections

91.417(a) And 91.417(b).

................................ ................................ ................................ ................................ ........ 11

C. The Extent Of Relief Geovironment Consulting Seeks And The Reason Geovironment

Consulting Seeks The Relief.

................................ ................................ ................................ ................................ ... 12

D. The Reasons Why Granting Geovironment Consulting Request Would Be In The

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

................................ ............................ 14

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How

The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule

From Which Geovironment Consulting Seeks Exemption.

................................ ................................ ....... 16

F. A Summary That Can Be Published In The Fede ral Register stating: The Rules From

Which Geovironment Consulting Seeks Exemption:

................................ ................................ .................... 28

G. A Brief Description Of The Nature Of Th e Exemption Geovironment Consulting Seeks: 28

H. Any Additional Information, Views, Or Arguments Available To Support Geovironment

Consulting's Request.

................................ ................................ ................................ ................................ ................. 28

CONCLUSION

................................ ................................ ................................ ................................ ................................ ....... 29

APPENDICES:

................................ ................................ ................................ ................................ ................................ ....... 30

APPENDIX

– A

................................ ................................ ................................ ................................ ................................ 31

APPENDIX

– B

................................ ................................ ................................ ................................ ................................ 31

APPENDIX

– C

................................ ................................ ................................ ................................ ................................ 33Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 3 

## GLOSSARY OF ABBREVIATIONS

3DR Solo

AGL

AOI

ATC

ATO

AV

CCO

CFR

COA

FAA

FAR

GIS

GPS

GCS

LOL

NAS

NOTAM

PIC

Section 333

SO

SOP

UA

UAS

VFR

VLOS

VMC

VTOL 3D Robotics Solo

Above Ground Level

Area of Interest

Air Traffic Control

Air Traffic Organization

Aerial Vehicle

Carbon Core Octocopter

Code of Federal Regulations

Certificate of Authorization

Federal Aviation Administration

Federal Aviation Regulation

Geographic Information System

Global Positioning System

Ground Control Station

Loss of Link

National Airspace System

Notice to Airman

Pilot in Command

FAA Modernization and Reform

Act of 2012 (FMRA) Section 333

Safety Observer

Standard Operating Procedures

Unmanned Aircraft

Unmanned Aircraft System

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions

Vertical Take

- Off and LandingGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 4 

## SUMMARY

Geovironment Consulting seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to

operate an Unmanned Airc raft System pursuant to Section 333 of the FAA Modernization and

Reform Act of 2012 (FMRA). This exemption will permit to operate an Unmanned Aircraft System

(UAS) for the commercial purpose of inspecting bridges and conducting aerial video and

photography of construction sites, real estate and landscape over certain areas of the United States.Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 5 

## INTRODUCTION AND INTERESTS OF THE

PETITIONER

Geovironment Consulting , LLC is a professional environmental consulting firm lead by its principal,

Andrew Minor , who has a B.S. in Environmental Management and a M.S. in Geographic Information

Systems (GIS) from the Un iversity of Redlands, Redlands, CA

. Please visit

http://geovironmentconsulting.com for additional experience and company information.

Geovironment Consulting has a relationship with several engineering firms, local municipalities,

real estate agents (both commercial and residential), private developers, construction companies,

and agricultural companies throughout Southern California. Geovironment’s core business is

performing environmental analysis for compliance with the California Environmental Quality Act

(CEQA) as well as local regulations. Currently, environmental resource surveys rely on

commercially purchased or freely available aerial or satellite imagery, which can be several years

old, taken du ring a different season, or too low resolution to be very useful for identifying habitat

or other features. The ability to collect current, high resolution aerial imagery would speed up the

environmental impact analysis process, which would provide a cost savings on projects and allow

Geovironment to be more competitive with its larger competitors. An additional market

Geovironment would like to service would be the agricultural sector. Mr. Minor’s family has a

history of farming in Southern California, beg inning in 1943. This connection to the farming

community would allow Geovironment to be uniquely positioned to enter an extremely fast

growing industry while also providing a valuable service that could result in savings of time,

money, water, and other re sources that are becoming more and more precious in California

agriculture.

Geovironment Consulting provides its clients with expertise and knowledge in advanced

geographic and environmental analysis solutions to increase efficiency, productivity and

effec tiveness. Geovironment has many years of experience in geographic and environmental

analysis

.

The objective of Geovironment Consulting’s aerial imagery and mapping operations is to provide

high quality imaging for a variety of commercial, public, and resid ential uses, specifically targeting:

• Construction sites

• Appraisals

• Real

- estate marketing

• Environmental analysis /habitat mapping

• Precision agricultureGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 6 

## BACKGROUND

Unmanned Aircraft Systems:

 3D Robotics Solo

Geovironment Consulting seeks an exemption to operate a 3D Robotics (3DR) Solo system for

compensation or hire within the NAS. The 3DR Solo is a vertical takeoff and landing (VTOL)

Unmanned Aircraft (UA) with a Remote Control system.

The 3DR Solo has a maximum gross weight of approximately 3.9 pounds, a length and width of 18

inches, height of 10 inches, and a maximum speed of 55 miles per hour (48 knots )

.

The 3DR Solo is equipped with 4 main rotors; utilizing Lithium Polymer batteries to power the

electric motors , onboard flight controller, and GoPro camera and gimbal

.

The 3DR Solo UAS will be operated by Geovironment Consulting will be registered in accordance

wit h 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration

,

and marked in accordance with 14 C.F.R. Part 45

, Identification and Registration Marking

.Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 7 

## BASIS FOR PETITION

Petitioner , Geovironment Consulting , pursuant to the provisions of the Federal Aviation

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

Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the

Administrator to commercially operate the 3DR Solo UAS in 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(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

unmanned aircraft and its operation, Geovironment Consulting 's operation of the 3DR Solo UAS

me ets the conditions of FMRA Section 333 and therefore, will not require an airworthiness

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

Accordingly, Geovironment Consulting requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for

maintenance that only apply to aircraft with an airworthiness certificate.

Geovironment Consulting submits that the requested relief is proper since a sufficient level of

safety will be ensured. Geovironment Consulting will use experienced personnel or technicians to

perform maintenance, alterations, or preventive maintenance the UAS using the methods,

techniques, and practices prescribed in the operating documents (i.e., M onthly Maintenance Log,

and 3DR Solo Instruction Manual). Furthermore, Geovironment Consulting will document and

maintain maintenance records for the 3DR Solo UAS.

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

limitations: Pilot in command , is requested by Geovironment Consulting to the extent necessary to

allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an

airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and

current requirements, that the PIC is able to safely operate the 3DR Solo UAS in a manner

consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

Geovironment Consulting seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

,

because the 3DR Solo UAS do es not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpar t H. As such, Geovironment Consulting submits that he will ensure that the

3DR Solo UAS is in an airworthy condition, prior to every flight, by determining that the UAS's are

in compliance with the operating documents (i.e., Monthly Maintenance Log, 3DR So lo Instruction

Manual), and that the aircraft are in a condition for safe flight. Geovironment Consulting also

seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the 3DR

Solo does not have a typical barometric altimeter onboard. However, altitude information of theGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 8

3DR Solo UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio

communications telemetry data link downlinks from the UAS to the GCS for active monitoring of

the flight path. This altitude information, combined with Geovironment Consulting 's operation of

the 3DR Solo UAS within visual line of sight, at or below 400 ft AGL, will ensure a level of safety

equivalent to Section 91.121.

Additio nally, Geovironment Consulting seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions

. Geovironment Consulting submits

that safety will not be affected by operation of the CCO w/ Wkm M and HH Blade 350QX3 AP UAS's

during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR),

with enough battery power to fly for a total duration of approximately 10 minutes for the intended

photo shoot or inspection and, assumin g normal speed, to fly after that for at least 2.5 minutes for

recovery and landing.

In accordance with 14 C.F.R. § 11.81, Geovironment Consulting provides the following information

in support of its petition for exemption:Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 9 

## Name and Address of Petitioner

A. Name And Address Of The Petitioner

The name and address of the Petitioner and point of contact is:

Geovironment Consulting

Attention : Andrew Minor, President

630 W 7 th Street

San Jacinto, CA 92583

Email: aminor@geovironmentconsulting.com



### B. The Specific Sections Of 14 C.F.R. From Which Geovironment Consulting

seeks Exemption

1. Geovironment Consulting Seeks Exemption From The Requirements Of

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and

(b) prescribe the following, in relevant 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. Geovironment Consulting 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. Geovironment Consulting Seeks Exemption From The Requirements Of

Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 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 100Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 10 nautical miles of the aircraft;

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

current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure

airport or an appropriate altimeter setting available before departure.



### 4. Geovironment Consulting Seeks Exemption From The Requirements Of

Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions

, subsection (b), states the

following:

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

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

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



### 5. Geovironment Consulting Seeks Exemption From The Requirements Of

Section 91.405 (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) of this section, have discrepancies

repaired as prescribed in part 43 of this chapter.



### 6. Geovironment Consulting 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 § 43.7 of this chapter.



### 7. Geovironment Consulting 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 unless, within the preceding 12

calendar months, it has had

--

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for returnGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 11 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. Geovironment Consulting Seeks Exemption From The Requirements Of

Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records

, subsections (a) and (b), states 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) of this section:

(1) Records of the 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 o f 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 the 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)(1) of this section shall be retained until

the work is repeated or superseded by other work or for 1 year after the work isGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 12 performed.

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

transferred with the aircraft at the time the aircraft is sold.

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

chapter shall be retained until the defects are repaired and the aircraft is approved

for return to service.



### C. The Extent Of Relief Geovironment Consulting Seeks And The Reason

Geovironment Consulting Seeks The Relief.

1. Extent Of Relief Geovironment Consulting Seeks And The Reason Geovironment

Consulting Seeks Relief From Section 61.113(a) And (b).

Relief from 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 holding a private pilot or higher level

certificate, as well as a current and valid airman medical certificate, and who has met certain flight

hour and currency requirements, to conduct the proposed UAS flight operations for compensation or

hire.

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 (2) The aircraft

does not carry passengers or property for compensation or hire.

As set forth more fully below, Geovironment Consulting submits that an equivalent level of safety

will be maintained because no PIC will be allowed to operate the 3DR Solo UAS unless that PIC

has met certain flight

- hour and current requirements, demonstrating that the PIC is able to safely

operate the 3DR Solo UAS in a manner consistent with the operations specifications as described in

this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate

distances from people, vessels, vehicles and structures.

Further, Geovironment Consulting submits that all flights of the 3DR Solo UAS, conducted by the PIC

pursuant to the grant of this Petition: (1) will be incidental to Geovironment Consulting 's business;

and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Geovironment Consulting Seeks And The Reason Geovironment

Consulting 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 Geovironment Consulting to determine that the 3DR Solo UAS is in airworthy condition prior

to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., theGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 13 Monthly Maintenance Log and 3DR Solo manuals.

Geovironment Consulting seeks the requested relief because the 3DR Solo UAS do es not require

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

Geovironment Consulting will ensure that the 3DR Solo UAS is in a irworth y c ondition ba s ed

upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and 3DR Solo

Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition

for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Geovironment Consulting Seeks And The Reason Geovironment

Consulting Seeks Relief From Section 91.121.IZ

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of

the 3DR Solo UAS, which utilize s a barometric pressure sensor, GPS equipment, and a radio

communications telemetry data link to downlink altitude information from the UA S to the PIC at the

ground control station (GCS). Since the FAA requires that any altitude information concerning UAS

operations be reported to air traffic control (ATC) in feet above ground level (AGL), Geovironmen t

Consulting seeks the requested relief because the 3DR Solo UAS ’s altimeter may be set on the ground

to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed opera tions, relief from 14 CFR 91.121 is sought to

the extent necessary to comply with the applicable conditions and limitations stated below. As more

fully set forth herein, an equivalent level of safety will be maintained since the 3DR Solo UAS is

equipped wi th a barometric pressure sensor and GPS equipment, which automatically ensures that a

ground level pressure setting will be established prior to each flight, and provides the PIC with

altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief Geovironment Consulting Seeks And The Reason Geovironment

Consulting Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in visual flight rules ( VFR ) is

requested to the extent required to allow flights of the battery powered 3DR Solo UAS during

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total

duration of 10 minutes to the first point of intended landing and, assuming normal cruising speed, to

fly after that for at least 2.5 minutes. Geovironment Consulting seeks the requested relief because

without an exemption from Section 91.151(b), the flight time duration of the battery powered 3DR

Solo UAS will severely constrain the practicality of any aerial video or still photo flight operations

that Geovironment Consulting proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the 3DR Solo operating documents and

Geovironm ent Consulting 's proposed operating limitations, ensure that Geovironment Consulting

will safely operate the battery powered 3DR Solo UAS during daylight hours in visual meteorologicalGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 14

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total

duration of 10 minutes to the first of intended landing and, assuming normal cruising speed, to fly

after that for at least 2.5 minutes.

5. Extent Of Relief Geovironment Consulting Seeks And The Reason Geovironment

Consulting Seeks Relief From Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) apply to aircraft

with an airworthiness certificate, Geovironment Consulting reque sts from these Sections because the

3DR Solo UAS do es not require airworthiness certificates. As set forth more fully below, the 3DR Solo

UAS meet s the conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, Geovironment Consulting will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS's the methods, techniques, and practices

prescribed in the UAS operating documents

, the Aerial Operations Manual, Monthly Mainten ance Log,

and 3DR Solo Instruction Manual). Furthermore, Geovironment Consulting will document and

maintain all maintenance records for the 3DR Solo UAS.



### D. The Reasons Why Granting Geovironment Consulting Request Would Be

In The Interest; That Is, How It Wo uld Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Geovironment Consulting to

safely, efficiently, and economically perform aerial video and photography of construction sites, real

estate, and lan dscape over certain areas of the United States. Geovironment Consulting’s use of the

3DR Solo UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits

to the economy. Notably, the benefits of Geovironment Consulting 's proposed operation of the 3DR

Solo UAS will be realized without implicating any privacy issues.

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

The 3DR Solo UAS are battery powered and serve as a safe, efficient, and economical alternati ve 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 the 3DR

Solo 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 3DR Solo UAS do es not

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video

and photography missions would result in fewer aircraft th at must be handled by air traffic control

during the ground, takeoff, departure, arrival, and landing phases of flight operations.Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 15 2. The Public Will Benefit From The Safety And Efficiency Of The 3DR Solo UAS.

Conducting aerial acquisitions with the 3DR Sol o UAS instead of manned aircraft, will greatly benefit

the public by drastically reducing levels of air and noise pollution generated during traditional aerial

video and still photography flight operations. By using battery power and electric motors, the 3 DR

Solo UAS produce no air pollution, and is the most viable environmentally conscious alternative to

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial

video and photography burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The

3DR Solo UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise

pollution, as the UA's are propelled by battery powered electric motors, rather than an internal

combustion engin e.

By using the 3DR Solo 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 completel y eliminated. Aside from the lack of flight crew

members located onboard the aircraft, the 3DR Solo UAS (weighing approximately 3.9 pounds, at its

maximum gross weight which (and with no fuel on board) has less physical potential for collateral

damage to l ife and property on the ground, and in the air, compared to the manned aircraft that

typically conduct similar operations (weighing approximately 6,000 pounds, and a fuel capacity of

180 gallons.

3. Performing Bridge Inspections and Aerial Video and Photography Operations With The

3DR Solo UAS Will Benefit The Economy.

In addition to being safe and efficient, the 3DR Solo UAS are also an economical alternative to using

manned aircraft to conduct simi lar aerial operations. As such, operation of the 3DR Solo UAS will

allow United States based companies, like Geovironment Consulting 's to remain competitive

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

En vironmental Protection Agency (“EPA”) regulatory actions phasing out aviation fuels, U.S. owned

and operated companies must adopt new and alternative technology in order to remain competitive.

Operating the battery powered 3DR Solo UAS is one such technolo gy that not only allows companies

greater operational flexibility compared to manned aircraft, but provides such flexibility without

high operational cost of a traditional manned aircraft.

By operating the 3DR Solo UAS, companies such as Geovironment Consulting 's can remain

competitive and profitable and therefore, provide greater job stability to employees and

contractors, which will ultimately contribute to that of the U.S. economy. Improved financial

performance of U.S. companies, thro ugh commercial use of the 3DR Solo UAS, provides a stable

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

companies to invest in research and development in order to remain competitive both in the United

States and abroad.Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 16

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

Geovironment Consulting 's proposed operation of 3DR Solo UAS will not implicate any privacy

issues. Specifically, t he 3DR Solo UAS will be operated only in compliance with operating documents

(i.e. Aerial Operations Manual, Monthly Maintenance Log, and the 3DR Solo Instruction Manual )

which requires property owner involvement as well as local law enforcement notificati on, and in

accordance with the Federal Aviation Regulations, including the minimum altitude requirements of

14 C.F. R. § 91.119.



### E. The Reasons Why Granting The Exemption Would Not Adversely Affect

Safety, Or How The Exemption Would Provide A Level Of Safety At Least

Equal To That Provided By The Rule From Which Geovironment Consulting

Seeks Exemption.

1. Reasons Why The 3DR Solo UAS Meet 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, Geovironment Consulting 's operation of the 3DR Solo UAS meet 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 a UAS to operate without airworthiness certification and sets

forth 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. Specifically, FMRA Section 333 states the

following, in part:

(a) In General.

-- 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.

-- In making the determination under subsection

(a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, a s 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

(2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification

under section 44704 of title 49, United States Code, is required for the operation of unmanned

aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that

certain unmanned aircraft systems may operate safely in the national airspace system, the

Secretary shall establish requirements for the safe operation of such aircraft systems in the

national airspace system.

In seeking this exemption, Geovironment Consulting submits that the 3DR Solo UAS can operate

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of theGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 17 3DR Solo UAS; (b) the pilot certifica tion requirement; and (c) the specific operating limitations.

a. The Specifications Of The 3DR Solo UAS Demonstrate Its Safe Characteristics.

The 3DR Solo UAS do es 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.

i. Technical Specifications Of The 3DR Solo UAS.

The technical specifications of the 3DR Solo UAS are set forth by the 3DR Solo Specifications and

Data Sheet, attached hereto as Exhibit A.

ii. The 3DR Solo UAS Autonomous Flight And Navigation Modes Enable The UAS To

Remain Within A Defined Operational Area.

The 3DR Solo may be operated in both manual and fully autonomous flight modes

. A complete

description of the flight and navigational modes of the 3DR Solo UAS is provided at pages 38

- 51 and

56

- 58 of the User Manual

, attached hereto as Exhibit B

.

iii. The 3DR Solo UAS IS Designed For Automatic Return To Home Point Or Hover In

The Event Of Loss Of The Control ler Signal Or Navigation.Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 18

If the signal between Solo and the controller is lost during flight, the controller displays the

“Controller signal lost” alert and Solo initiates Return Home. If signal is recovered while returning

home, the controller displays the “ Signal recovered” alert and provides the option to regain manual

control by pressing the Fly button

.

If Solo loses GPS during flight, it switches into Fly:Manual mode so the PIC can maintain control of

the UAS . If Solo recovers GPS during flight, Solo swit ches from Fly:Manual to standard flight (Fly),

and GPS positioning activates.

If another alert occurs while Solo is in Fly:Manual, Solo cannot return home and instead initiates a

non

- positioned landing at its current location.

A complete description of the Failsafe Functions of the 3DR Solo UAS are set forth at pages 2 5

- 29

and 52

- 55 of the 3DR Solo User Manual, attached hereto as Exhibit B

.

iv. The 3DR Solo GCS And Its Operation.

A complete description of the operation and specifications of the 3DR Solo GCS and flight control

software is provided at pages 1

- 5 of the User Manual. The 3DR Solo User Manuals are attached

hereto as Exhibits B

.

b. Flight Operations Of 3DR Solo UAS ARE Limited To The Line Of Sight Of A Certificated

Pilot in Command With A Safety Observer.

Geovironment Consulting will only utilize certificated pilots who possess a current and valid

airman medical certificate to act as a pilot in command (PIC) of the 3DR Solo UAS. Additionally, a

safety observer will assist all pilots during flight time.

c. Flights Of 3DR Solo UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Geovironment Consulting proposes to commercially operate 3DR Solo UAS

for the special purpose of conducting aerial video and photography over certain areas of United

States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following aircraft

described in the operating doc uments, rotorcraft UAS's weighing less than 55 pounds

maximum gross weight: 3DR Solo Unmanned Aircraft Systems. Proposed operations of any

other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption wil l be limited to conducting operations for the

purpose of aerial video and photography.

3. The UA may not be flown at an indicated airspeed exceeding 20 knots.Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 19 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL),

as indicat ed by the procedures specified in the operating documents unless a special request

is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UA's must be operated within visual line of sight (VLOS) of the PIC at all times. This

re quires 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.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. All

o perations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS

requirement as long as the PIC always maintains VLOS capability. The SO 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 SO can perform

the functions prescribed in the operating documents.

7. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding

other air traffic and other ground based obstacles/obstructions and is not permitted to

operate the camera or other instruments.

8. The operating documents and the grant o f exemption must be accessible during UAS

operations and made available to the Administrator upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the

procedures outlined in the operating docum ents, the conditions and limitations contained in

the grant of exemption 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 docume nts. It is the operator’s responsibility to track such revisions and

present updated and revised documents to the Administrator upon request. The operator

must also present updated and revised documents if it petitions for extension or amendment

to the gra nt of exemption. If the operator determines that any update or revision would

affect the basis upon which the FAA granted the exemption, then the operator must petition

for 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.

9. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe op eration 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. The Ground Control Station must be

included in the preflight inspection. All mainten ance and alterations must be properly

documented in the aircraft records.

10. Any UAS that has undergone maintenance or alterations that affect the UAS operation orGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 20 flight characteristics, e.g. replacement of a flight critical component, must undergo a

functio nal test flight. The PIC who conducts the functional test flight must make an entry in

the aircraft records.

11. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable

components, items, or equipment, not already covered in the relevant sections of the

operating documents.

12. The operator must follow the UAS manufacturer’s aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.

13. The operator must carry out its maintenance, inspections, and r ecord keeping requirements,

in accordance with the operating documents, maintenance, inspection, alterations, and

status of replacement/overhaul component parts must be noted in the aircraft records,

including total time in service, description of work acc omplished, and the signature of the

authorized person returning the UAS to service.

14. Each UAS's operated under this exemption must comply with all manufacturer Safety

Bulletins.

15. The authorized person must make an entry in the aircraft record of the correc tive action

taken against discrepancies discovered between inspections.

16. The PIC must possess at least a private pilot certificate and at least a current third

- class

medical certificate.

17. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels,

vehicles and structures. PIC qualification flight hours must be logged in a manner consistent

with 14 C.F.R. §61.51(b). Flights for the purposes of training the operator’s PIC's are

permitted under the terms of the exemption. However, tra ining 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 a ppropriate distance from

nonparticipants in accordance with 14 C.F.R. § 91.119.

18. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). If flight at

night is required, a special request will be made at the FAA office closest to prop osed area of

operations. Flights under special visual flight rules (SVFR) are not authorized.

19. The UA may not operate within 5 nautical miles of an airport reference point as denoted on aGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 21 current FAA published aeronautical chart unless a letter of agreemen t with that airport’s

management is obtained, and the operation is conducted in accordance with a NOTAM as

required by the operator’s COA. The letter of agreement with the airport management must

be made available to the Administrator upon request.

20. 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.

21. If the UA loses communications or loses its GPS signal, it must return to a pre

- determined

locat ion within the planned operating area and land or be recovered in accordance with the

operating documents.

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

accordance with the operating documents.

23. The PIC is prohibite d from beginning a flight unless (considering wind and forecast weather

conditions) there is enough power to fly at normal cruising speed to the intended landing

point and land the UAS with 25% battery power remaining.

24. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

Authorization (COA) prior to conducting any operations under the grant of exemption. This

COA will also require the operator to request a Notice to Airman (NOTAM) no t more than 72

hours in advance, but not less than 48 hours prior to the operation. All operations shall be

conducted in accordance with airspace requirements in the ATO issued COA including class

of airspace, altitude level and potential transponder requi rements.

25. All aircraft operated in accordance with the exemption must be identified by serial number,

registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number)

markings in accordance with 14 C.F.R. part 45, Subpart C. Markings mus t be as large as

practicable.

26. Before conducting operations, the radio frequency spectrum used for operation and control

of the UAS must comply with the Federal Communications Commission (FCC) or other

appropriate government oversight agency requirements.

27. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at

the Ground Control Station of the UAS any time the UAS is operating. These documents must

be made available to the Administrator or any law enforcement official upo n request.

28. The UAS must remain clear and yield the right of way to all manned aviation operations and

activities at all times.

29. The UAS may not be operated by the PIC from any moving device or vehicle.

30. Flight operations must be conducted at least 500 fee t from all nonparticipating personsGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 22 (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles,

and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UAS 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 and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted permission 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, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not

present an undue hazard to those persons per § 91.119(a).

31. All operations shall be conducted over private or controlled

- access property with

permission from the land owner/controller or authorized representative. Permission from

land owner/controller or authorized representative will be obtained for each flight to be

conducted.

32. 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

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

www.ntsb.gov.

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

Not Adversely Affect Safety.

Geovironment Consulting submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 3DR Solo UAS

unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements,

that the PIC is able to safely operate the 3DR Solo UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures.

Considering Geovironment Consulting 's proposed area of operations, and the operating limitations

set forth

- above; 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 3DR Solo UAS, Geovironment Consulting submits that the additional manned

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

skills necessary for Geovironment Consulting 's specific proposed flight operations.Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 23 The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153,

11156, 11158, 11159, 11160, 11161, 11445).

Geovironment Consulting will not allow any PIC to operate the 3DR Solo UAS unless that PIC has

demonstrated, by meeting minimum flight

- hour requirements of the 3DR Solo UAS training and

currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a manner

consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. §

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours

as a UAS pilot operating the same make and model of UAS to be used for operations under the

exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in

the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was

obtained in compliance with applicable regulations will ensure an equivalent level of safety during

Geovironment Consulting 's proposed operations. The Administrator has held that prior documented

flight experience that was obtained in compliance with applicable regulations would ensure safe

operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a

manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at

least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No.

11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot

operating the same make and model of UAS to be used for operations under the exemption. For

clarification, the FAA considers these minimum hour requirements to be inclusive rather than

additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and

the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No.

11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the

petitioner’s proposed operations. The FAA also finds that prior documented flight experience that

was obtained in compliance with applicable regulations would satisfy this requirement. Training,

proficiency, and experience

- building flights can also be conducted under the grant of exemption to

accomplish the required flight time. During training, proficiency, and experience

- building flights the

PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 24

Accordingly, Geovironment Consulting will ensure safe operations by not allowing any PIC to

operate the 3DR Solo UAS unless that PIC has demonstrated, by meeting minimum flight

- hour

and currency requirements, that the PIC is able to safely operate the 3DR Solo UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to

every flight, Geovironment Consulting will ensure that the 3DR Solo UAS is in an airworthy condition

based upon the UAS’s compliance with its operating documents and as stated in the conditions and

limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) sp ecific to

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

information of the 3DR Solo UAS will be provided to the PIC via GPS equipment and a radio

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring

of the flight path and altitude. This altitude information, combined with Geovironment Consulting 's

operation of the 3DR Solo UA S within visual line of sight, at or below 400 feet AGL, will ensure a level

of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment

installed on board the aircraft. Prior to each flight, a zero altitude initiation point is automatically

established by the UAS at ground level. FAA has previously granted relief from Section 91.121

specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11445).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b) as a result of (1) the technical specifications of the 3DR Solo UAS; (2) the limitations on the

proposed flight operations; and (3) the location of the proposed flight operations. Accordingly,

Geovironment Consulting will ensure that he will safely operate the battery powered 3DR Solo UAS

during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 10

minutes to the first point of intended and, assuming normal cruising speed, to fly after that for atGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 25 least 2.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the 3DR Solo UAS the limitations on

the proposed flight operations and the location of the proposed operations, will ensure an equivalent

level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the

3DR Solo UAS provide audible and visual warnings to the PIC at the GCS when the UA's experiences

low battery voltage, the first warning occurring at approximately 33% remaining battery power, and

again at approximately 10% remaining battery power. At the critically low battery level, the 3DR Solo

UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that

safety is not adversely affected when the technical characteristics and operating limitations of the

UAS are considered. Relief has been granted for manned aircraft to operate at less than the

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650.

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS in

circumstances similar in all material respects to those presented herein (e.g. Exemption Nos. 8811,

10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136,

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11445).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), And 91.417(a) &(b) Would Not Adversely Affect Safety.

In seeking this exemption, Geovironment Consulting submits that the equivalent 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), and 91.417(a) & (b) will be met because

Geovironment Consulting will use trained technicians to perform maintenance, alterations, or

preventive maintenance on the UAS's using the methods, techniques, and practices prescribed in

the operating documents i.e., the Operations Manual, Monthly Maintenance Log, and 3DR Solo

Instruction Manual. Furthermore, Geovironment Consulting will document and maintain all

maintenance records for the 3DR Solo UAS.

Since the 3DR Solo UAS will be inspected as prescribed by the operating documents,

Geovironment Consulting will maintain the equivalent level of safety established by Sections

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 3DR Solo User Manual is attached hereto

as Exhibit B ; a copy of the 3DR Solo UAS Maintenance LOG is attached hereto as Exhibit C

.

Likewise, the exemption sought will not adversely affect safety because Geovironment Consulting

will use trained technicians to perform maintenance, alterations or preventive maintenance on

the UAS using the methods, techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety Established

by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 3DR Solo UAS's willGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 26

be performed by trained technicians. Maintenance will be documented and maintained utilizing

the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely

affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of Geovironment Consulting 's proposed operating limitations, the operating

documents, and the technical aspects of the 3DR Solo UAS, Geovironment Consulting submits that

safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a),

91.407(a)(1) and (a)(2), 91.409(a) (2), and 91.417(a) and (b). The FAA has previously granted

relief specific to UAS in circumstances similar, in all material respects, to those presented herein

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11445).

7. 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, Geovironment Consulting requests that the FAA prescribe

special conditions for the intended operation of the 3DR Solo 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 §§ 61. 113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a),

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

operation of the UA's for the limited purpose of conducting aerial video and photography over certain

a reas of the United States for compensation or hire. 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 further, provides the authority for such UAS to operate without

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

operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C. F.R. §21.16, for

operation of the 3DR Solo UAS, 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 C onditions, 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, it may prescribe 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, aircraf t engine or propeller as the FAA

finds necessary to establish a level of safety equivalent to that established in the regulations. See 14Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 27 C.F.R. § 21.16. in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe

special conditions for Geovironment Consulting 's intended operation of the 3DR Solo 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. Par t 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b),

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 28



### F. A Summary That Can Be Published In The Federal Register stating:

The Rules From Which Geovironment Consulting Seeks Exemption:

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

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).



### G. A Brief Description Of The Nature Of The Exemption Geovironment

Consulting Seeks:

This exemption will permit Geovironment Consulting to commercially operate an Unmanned Aircraft

System (UAS) for the purpose of conducting aerial video and photography over certain areas of the

United States.



### H. Any Additional Information, Views, Or Arguments Available To

Support Geovironment Consulting '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, Geovironment Consulting 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 poses a threat to national security and further,

provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Geovironment Consulting will operate the 3DR Solo UAS safely in

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat

to national security.Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 29 

## CONCLUSION

As set forth herein, Geovironment Consulting seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit

safe operation of the 3DR Solo UAS commercially, without an airworthiness certificate, for the

limited purpose of conducting aerial video and photography over certain areas of the United

States. 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 Geovironment Consulting to safely, efficiently, and economically

operate the 3DR Solo UAS commercially within the NAS.

WHEREFORE

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

Reform Act of 2012, Section 333, Geovironment Consulting 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(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b), and permit Geovironment Consulting to operate the 3DR Solo UAS commercially for

the purpose of bridge inspections and conducting aerial video and photography over certain areas

of the United States.

Dated: Nov 25, 2015

Respectfully submitted,

Andrew J. Minor

Geovironment ConsultingGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 30 

## APPENDICES:

A

– 3DR Solo Specifications

B

– 3DR Solo User Manual

C

– Monthly Maintenance LogGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 31 

### APPENDIX

– A



## 3DR SOLO TECHNICAL SPECIFICATIONS

Geovironment Consulting only utilizes safe and reliable UAS s. 3D Robotics is an industry leader in

small UAS production. 3DR UAS s are loaded with ground breaking software enabling the user to set

parameters which will not allow flight into controlled airspace. Parameters can also be set to limit

flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined

and set distance. In addition, 3DR software provides real

- time altitude and location information to

the PIC via the linked app

, and 3DR Solo Radio Control Transmitter

.

Solo is a quad

- rotor aerial vehicle powered by the 3DR Pixhawk 2 autopilot system and APM:Copter

f light control software. Solo communicates with the controller and Solo app over the 3DR Link secure

Wi

- Fi connection.

Autopilot: 3DR Pixhawk 2

Flight code: ArduPilot Copter

Control: 3DR Solo Controller

Wireless communication: 3DR Link 1.0

Frequency: 2.4 GHz

Height: 10 in. (25 cm)

Motor

- to

- motor dimension: 18 in. (2 6 cm)

Propulsion: 880 KV motors, two clockwise rotating motors and two

counterclockwise rotating motors

Propeller: 10 in. x 4.5 in. (25 cm x 11.4 cm)

Weight with battery: 3.3 lbs. (1.5 kg)

Controller battery life: 3 hours

Extended controller battery life: 6 hours

Controller battery: Li

- ion 2600 mAh 7.2 Vdc (5200 mAh for extended battery)

Power: Electric (rechargeable lithium polymer battery)

Battery: Lithium polymer, 5200 mAh, 14.8 Vdc

Battery weight: 1 lb. (.5 kg)

Estimated flight time: 25 minut es*

Maximum altitude: 328 ft. (100 m)

Range: 0 .5 miles** (.8 km)

Payload capacity: 1.1 lbs. (500 g)

Cruise speed: 5.7 mph (2.5 m/s)

Maximum speed: 55 mph (25.5 m/s)

Maximum climb rate: 11 mph (5.0 m/s)

Maximum descent rate: 5.5 mph (2.5 m/s)

Headwind limitation: 25 mph (11 m/s)

Crosswind limitation: 25 mph (11 m/s)

Camera: Streaming video compatible with GoPro® HERO 3, 3+ or 4

Full compatibility with GoPro® HERO 4

Solo app compatibility: iOS 8.0 or later / Android 4.3 or later

Operating te mperature: 32° F

- 113° F (0° C

- 45° C)

Operating relative humidity: 0

- 85% RH

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style, and pilot skill. Listed fl ight

time applies to elevations less than 2,000 ft above sea level.

**Range varies with location, antenna orientation, background noise and multi

- path.



### APPENDIX

– BGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 Page 32 

## 3DR Solo

– Manufacturer's User Manual

https://3drobotics.com/wp

- content/uploads/2015/11/v8_11_20_15.pdfGeovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015

Geovironment Consulting, LLC Section 333 Exemption Submission version 1.0 Nov 25, 2015 A Page 33 

### APPENDIX

– C



## Monthly Maintenance and Repair Log

Geovironment Consulting will be using and individual fight time, monthly maintenance and repair log

book for each unit in operation the following is an example of the minimum logged information:

Aircraft:

N

- Number:

Hours:

Date:

Date Issue

Discovered Date

Issue

Resolved Issue Description/

Maintenance Conducted Repair/Maintena nce

Performed By

Airframe

Motors

Propellers

Flight Control Update

Gimbal

Misc