Date: Aug 15th

, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of GeoSpec 3D, LLC for an Exemption Pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012

To Whom it May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 

C.F.R. Part 11, GeoSpec 3D, LLC. ("GeoSpec 3D") hereby applies for an exemption from the Federal

Aviation Regulations ("FARs") identified below to allow commercial operation of small unmanned aerial 

vehicles (i.e., "small unmanned aircraft" or "UAS") for the purpose of conducting controlled flights for aerial 

surface and structural inspection of public and private facilities such as wind turbines, cell towers, bridges, 

etc. Additionally, provide aerial photography, mapping and data collection services for real estate, golf 

courses and agriculture.

This petition for exemption is created based on information outlined in this Petition for Exemption, as 

well as but not limited to these accompanying GEOSpec 3D documents; 

1. Flight Operations Manual and;

2. Operations Manuals"

(collectively referred to as "GEOSpec 3D Operations Manuals")

3. User Guide and;

4. User Manual

(collectively referred to as "Manufacturer's Manual").

1

GEOSpec 3D submits these as well as other GEOSpec 3D supporting materials as confidential 

documents pursuant to 14 C.F.R. § 11.35 (b), as the materials contain confidential commercial and/or 

proprietary information that the GEOSpec 3D has not and will not share with others. Additionally, these

documents contain operating conditions and procedures that are not generally available to the public and

are protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.

1The term "Manufacturer's Manual" also includes all relevant manufacturer publications, including, but not

limited to: operations and flight manuals, user guides, component maintenance manuals, pilot training

manuals, service information letters and, safety/service bulletins).
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Aug 15th, 2015

Page 2

This Petition is organized as follows:

I. Petitioner

II.Description of Proposed Operations

A. High level, Traditionally Dangerous Aerial Public and Private Facilities and Site Inspections

B. Real Estate Public and Private Aerial Photography, Mapping and Data Collection Services

II.Relevant Statutory Authority

IV. GEOSpec 3D Proposed GEO-UAS Operations Meet the Requirements of Section 333 of the

Reform Act

A. Approval is Warranted Based on the GEO-UAS's Size, Weight, Speed, and Operational 

Capability

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the Operations

Manuals

V. Regulations From Which Exemption is Requested

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

C.14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

E. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14 C.F.R. § 91.203(a) 

and (b): Carrying Civil Aircraft Certification and Registration

H. 14 C.F.R. § 91.103: Preflight Action

I. 14 C.F.R. § 91.109(a): Flight Instruction

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

K. 14 C.F.R. § 91.121: Altimeter Settings

 L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

VI. Drug and Alcohol Program

VII. Public Interest

VIII. Privacy

IX. Federal Register Summary

X. Conclusion
U.S. Department of Transportation

Aug 15th, 2015

Page 3

I. DESCRIPTION OF PETITIONER

Based in Henderson, Nevada, GEOSpec 3D has goals to become a well-known aerial inspection company 

focusing on facilities inspection where a very high level of danger exists for companies where traditional

methods use for inspection such as; (1) the use of helicopters with an inspector on a wire deployed from the 

side door of the aircraft, (2) personnel climbing 100 foot plus all types of towers can and do take lives. 

GEOSpec 3D will perform such inspection services for wind turbines, cell towers, water towers, antennas, 

bridges, and other structures where human life would be in danger. The majority of these operations will be 

conducted specifically in airspace previously reviewed and approved by the FAA for the construction of 

towers, wind turbines, high level bridges and other facilities in a controlled area and will not create 

additional hazard in the NAS. Additionally the GEOSpec 3D will provide like-minded inspection services 

for contractor clients who need aerial photography of real estate construction sites, golf course sites, local 

city and county utilities, parks, sports construction sites, etc. GEOSpec 3D plans eventually in expanding to 

mapping for precision agriculture and water conservation. GEOSpec 3D ’s President Jason Orton is 

extremely proficient at UAS PIC Operations with more than 2500 hours operating unmanned aircraft

overseas, and additionally holds a current FAA ATP pilot's license. GEOSpec 3D seeks an exemption to 

allow for the commercial operations of small, 55lbs GEO-UAS to facilitate this high level, traditionally 

dangerous to human life, above ground aerial facilities and construction site inspection.

The contact information for Petitioner is as follows:

Jason Orton

President

GeoSpec 3D, LLC.

PO Box 530193

Henderson, NV 89053

512-535-8007

Jason.Orton777@Gmail.com

II.DESCRIPTION OF PROPOSED OPERATION

GEOSpec 3D seeks an exemption pursuant to Section 333 of the Reform Act to operate the UAS DJI 

Inspire 1 and AscTech Falcon 8 also known as (GEO-UAS) for the proposed operations discussed below. 

All GEO-UAS operations will occur under tightly controlled conditions at locations where GEO Spec 3D

has received permission to operate from the landowner, controller or authorized representatives. The

proposed GEO-UAS operations will be conducted in accordance with the conditions and limitations of this 

Petition for Exemption and GEOSpec 3D Operations Manuals. As detailed in GEOSpec 3D Operations 

Manuals, all GEO-UAS operations will be limited to daytime VFR conditions, within visual line-of-sight 

("VLOS") of the operator and or (“VO”) visual observers, in uncontrolled airspace, and will occur at least 5 

miles away from an airport. Moreover, GEOSpec 3D Operations Manuals incorporate redundant 

safeguards to assure that the aircraft does not travel outside the controlled area of GEO-UAS operations, 

including GPS "geo-fencing" technologies.
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A. High level, Traditionally Dangerous Aerial Public and Private Facilities and Site Inspections

GEOSpec 3D seeks to use small GEO-UASs for the purpose of conducting high level, controlled 

flights for aerial surface and structural inspection of public and private facilities such as wind turbines, cell 

towers, bridges, etc. GEOSpec 3D has tailored its operations to meet the requirements established by the

FAA in prior grants of exemptions authorizing commercial use of GEO-UAS in high level, aerial facilities 

and industrial site inspection including:

 ATAC Global LLC (Exemption No. 11794)

 Legend Creative Group (Exemption No. 11789)

 Precision Design & Drafting, Inc. (Exemption No. 11783)

 RS&H, Inc. (Exemption No. 11772)

 Trudeau, Realtor® (Exemption No. 11138)

 Eagle Eye Aeronautical Imaging LLC (Exemption No. 12337)

 Alon Sicherman (Exemption No. 11728)

 Sokoler Medley (Exemption No. 11341)

 ASYMMETRIC TECHNOLOGIES, LLC (Exemption No. 11171)

All GEO-UAS high level, aerial facilities and construction site inspection operations will be 

conducted on GEOSpec 3D and other approved property in a controlled area, away from spectators and 

persons not involved. All GEO-UAS high level, aerial facilities and construction site inspection will be 

conducted during daylight hours, VFR conditions, at altitudes below 400' AGL. As set forth below, 

GEOSpec 3D operations provide a superior level of safety and quality compared to performing the same 

aerial photography and inspection work using conventional fixed-wing aircraft or helicopters.

B. Real Estate Public and Private Aerial Photography, Mapping and Data Collection Services

GEOSpec 3D seeks to use small GEO-UAS for the purpose of conducting high level, aerial 

inspections of facilities and industrial sites, and for conducting real estate and agriculture aerial 

photography, mapping and data collection services. Traditional methods of high level, aerial facilities and 

industrial site inspection are extremely costly and present uncalled for risk, physical harm, serious injury

and death to manned aircraft participants and dangers for participants, employees and pedestrians on the 

ground. Further, the use of traditional aircraft exposes extreme dangers from low level aircraft engine failure 

making recovery or emergency landings next to impossible. The use of small GEO-UAS mitigates these

hazards and is ultimately a much safer method of performing these and most other types of high level, 

aerial facilities and industrial site inspection and real estate and agriculture aerial photography, mapping 

and data collection services.

Conventional operations using rotorcraft and fixed-wing aircraft in low level operations present risks 

associated with vehicles weighing thousands of pounds and carrying large amounts of fuel. It is important 

to note that the use of small GEO-UAS in this area are safer and more cost effective, and deliver higher

quality of data and information far superior to that of any other system. Small GEO-UAS are more reliable, 

and allow for the collection, dissemination, and storage of visual and other sensory data with greater 

precision and duration. Small GEO-UASs are also capable of accessing and inspecting areas that would 

otherwise be inaccessible to humans and cannot be completed with conventional aircraft.
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Aug 15th, 2015

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III. RELEVANT STATUTORY AUTHORITY

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely

accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to 

Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in 

the National Airspace System ("NAS") where it is safe to do so based on the following considerations:

● GEO-UAS's size, weight, speed and operational capability;

● Operation of the GEO-UAS in close proximity to airports and populated areas; and

● Operation of the GEO-UAS within the visual line of sight of the operator.

Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. See 49 U.S.C. § 106(f) (defining the authority of the Administrator); 49 U.S.C. § 44701(f)

(permitting exemptions from §§ 44701(a), (b) and; §§ 44702 – 44716, et seq.). A party requesting an

exemption must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2)

would not adversely affect safety (or how it would provide a level of safety at least equal to the existing

rules). See 14 C.F.R. § 11.81 (petitions for exemption).

IV. GEOSpec 3D’s PROPOSED GEO-UAS OPERATIONS MEET THE REQUIREMENTS OF

SECTION 333 OF THE REFORM ACT

The small GEO-UAS operations proposed by GEOSpec 3D in this Petition for Exemption qualify for 

expedited approval pursuant to Section 333 of the Reform Act as each of the statutory criteria and relevant 

factors are satisfied.

A. Approval is Warranted Based on the GEO-UAS's Size, Weight, Speed, and Operational 

Capability

A Grant of Exemption is appropriate for operations conducted using GEO-UAS due to its size weight, speed,

and operational capability.

 GEO-UAS have been approved for use in prior Section 333 Grants of Exemption from the FAA.

2

 GEO-UAS weigh less than 55 pounds, including payload.

2

See e.g., Grant of Exemption to Legend Creative Group (Exemption No. 11789) Precision Design & 

Drafting, Inc. (Exemption No. 11783), RS&H, Inc. (Exemption No. 11772).
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 GEO-UAS will not be flown at a ground speed in excess of 50 knots.

 Altitude information will be generated by equipment onboard the UA as specified using GPS

triangulation, digitally encoded barometric altimeter, radio altimeter, or any combination thereof. 

This information will be transmitted to the pilot via telemetric data feed.

 The GEO-UASs will have system redundancies and independent functionality to ensure the overall

safety and predictability of the system. If connection to the remote control or ground control station 

is lost, failsafe systems will permit the GEO-UAS to return to a predetermined location and safely

land without injury or damage.

 The radio frequencies used for operations and control of the GEO-UAS comply with the Federal 

Communications Commission ("FCC") and other appropriate government oversight agency

requirements. The operating frequency for the GEO-UAS is 2.4 GHz. 

If the same operations were conducted using a helicopter, the aircraft's take-off weight would likely

exceed 6,000 pounds carrying a pilot, camera operator and VO-visual observer- navigator. The difference

in weight between the GEO-UAS and a helicopter significantly reduces the potential harm to the

participating and non- participating individuals or property in the event of an accident or incident. In

addition, the risk to the onboard pilot and camera operator is eliminated.

B. Approval is Warranted Based on the Operational Restrictions Set Forth in GEOSpec 3D

Operations Manuals

GEOSpec 3D’s Operations Manuals and the Manufacturer's Manual for the selected GEO-UASs will 

contain all the procedures and limitations necessary to safely and successfully perform the operations 

specified in this Petition for Exemption. To assist the FAA in making a safety assessment of GEOSpec 

3D’s proposed operations, below is a summary of operational limitations and conditions that GEOSpec 3D 

will adhere to, and which will ensure an equivalent or higher level of safety to operations conducted under

current regulatory guidelines:

1. The GEO-UAS weighs less than 55 pounds, fully loaded.

2. 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 operation.
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3. All GEO-UASs operated under the Grant of Exemption will be identified by serial number, registered 

in accordance with 14 CFR part 47, and have identification (N-Number) markings in accordance with 

14 CFR part 45, Subpart C. Markings will be as large as practicable.

4. Minimum crew for each flight operation will consist of a pilot, who will be Pilot- in Command 

("PIC") of the GEO-UAS, and one or more Visual Observers ("Observer") as necessary to safely

conduct the mission.

5. PICs shall possess at least a Sport or Private Pilot's Certificate and current Class II Medical Certificate

and/or a valid state driver’s license. The PIC will also meet the flight review requirements specified

in 14 C.F.R 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

6. The UA shall be operated within VLOS of the PIC and Observer at all times. The PIC must use 

human vision unaided by any device other than corrective lenses, as specified on the PIC's FAAissued medical certificate.

7. The PIC and Observer designated for any operation will be able to communicate verbally at all times.

8. Electronic messaging or texting will not be permitted during flight operations.

9. The additional requirements identified in the Grant of Exemption shall be added to the GEOSpec 3D 

Operations Manuals. The Operations Manuals will be maintained and made available to the Administrator 

upon request. If a discrepancy exists between the conditions and limitations in the Grant of Exemption and 

GEOSpec 3D Operations Manuals, the conditions and limitations in the Grant of Exemption shall take

precedence and must be followed. Otherwise, GEOSpec 3D shall follow the procedures outlined in their 

Operations Manuals.

10. GEOSpec 3D may update or revise its Operations Manuals. Revisions will be tracked and a revised

copy of the Manual will be provided to the Administrator upon request. GEOSpec 3D will also present an

updated and revised Operations Manuals if it petitions for extension or amendment to its Grant of Exemption.

If an update or revision would affect the basis upon which the FAA grants the exemption, GEOSpec 3D will 

seek an amendment to its Grant of Exemption. GEOSpec 3D will contact the FAA’s GEO-UAS Integration 

Office (AFS-80) if questions arise regarding updates or revisions to the operating documents.

11. GEOSpec 3D Operations Manuals and its Grant of Exemption will be available to the

PIC at the ground control station anytime the GEO-UAS is operating.

12. The PIC is prohibited from beginning a GEO-UAS flight unless (considering wind and forecast 

weather conditions) there is enough power to fly to the first intended point of landing, and assuming normal 

cruising speed, to fly after that for at least 10 minutes.
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13. Maximum total flight time for each operational flight using the GEO-UAS will be limited to 40 

minutes or the amount of time the GEO-UAS can be flown and still maintain a reserve battery power of no 

less than 25%, whichever occurs first.

14. Flights will be operated at an altitude of no more than 400 feet AGL and will never enter navigable 

controlled airspace without prior written authorization and approval from the FAA. In the event the structure

being inspected exceeds 400 feet AGL, the GEO-UAS will not be operated more than 100 feet above the 

highest point on the structure, and no more than 20 feet horizontally from the structure.

15. Flight operations must be conducted at least 500 feet from all nonparticipating persons. (persons 

other than the PIC, VO, operator trainees or essential personnel), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or 

debris in the event of an accident. The operator must ensure that nonparticipating persons remain under 

such protection. If a situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately 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, VO, operator trainees or essential persons do not present an undue

hazard to those persons per § 91.119(a).

16. 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.

17. The UA may not operate within 5 miles of an airport reference point as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the 

operation is conducted in accordance with a NOTAM as required by the GEOSpec 3D COA. The letter of

agreement with the airport management will be made available to the Administrator upon request.

18. Prior to each flight the PIC shall inspect the GEO-UAS to confirm that it is in a condition safe for

flight. The pre-flight inspection will account for all discrepancies, e.g. inoperable components, items, or

equipment, not already covered in the relevant sections of the operating documents. The PIC shall not 

operate the GEO-UAS if the inspection reveals a condition that affects the safe operation of the GEO-UAS

until the necessary maintenance has been performed and the GEO-UAS is found to be in a condition for safe

flight. The ground control station shall be included in the preflight inspection. All maintenance and 

alternations must be properly documented in the GEO-UAS records as required by GEOSpec 3DOperations 

Manuals.
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19. GEOSpec 3D will carry out its maintenance, inspections, and record keeping requirements in 

accordance with the Operations Manuals. Maintenance, inspection, and alterations will be noted in the GEOUAS records, including total time in service, description of work accomplished, and the signature of the

authorized person returning the GEO-UAS to service.

20. Any GEO-UAS that has undergone maintenance or alterations that affect the GEO-UAS

operation or flight characteristics (e.g., replacement of a flight critical component) must undergo a functional

test flight in accordance with GEOSpec 3D Operations Manuals. The PIC who conductsthe functional test

flight must make an entry in the GEO-UAS aircraft records of the flight. The requirements and proceduresfor a

functional test flight and GEO-UAS record entry shall be included in the GEOSpec 3D Operations 

Manuals.

21. The GEO-UAS will be operated and maintained according to the Manufacturer's

Manuals and any required manufacturer Safety/Service Bulletins.

22. Prior to the operation, a Mission Packet will be created in accordance with the requirements on 

GEOSpec 3D Operations Manuals.

23. GEOSpec 3D will obtain an Air Traffic Organization ("ATO") issued Certificate of Waiver or 

Authorization, otherwise known as a COA, prior to conducting any operations under this Grant of 

Exemption. A NOTAM will be issued as required by the COA. All operations will be conducted in

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements if any.

24. All required permissions and permits will be obtained from territorial, state, county or city

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies.

25. If the GEO-UAS loses communication with the pilot, it will have the capability to return to a predetermined location within the operational area and land safely.

26. Contingency plans will be in place to safely terminate flight if there is a loss of communication 

between the PIC and the Observer.

27. The GEO-UAS will have the capability to safely abort flight in the case of unpredicted obstacles or

emergencies.

28. PICs and Observers will have at least a current Class II Medical Certificate and/or a valid state 

driver’s license.

29. Prior to conducting commercial UAS flight operations, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of 200 flight cycles and 25 hours total time as a 

UA rotorcraft pilot and at least 10 hours logged as a GEO-UAS pilot with a similar GEO-UAS type. This 

requirement can be completed as an “enthusiast PIC” in order to meet such “commercial PIC requirements”. 
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30. Prior to conducting commercial UAS flight operations, the PIC will have accumulated and logged, 

in a manner consistent with 14 CFR § 61.51(b), a minimum of 54 CFR §61.51(b), a minimum of 10 logged 

hours as GEO-UAS pilot operating the make and model of GEO-UAS to be utilized for operations under the

exemption and thirty take-offs and thirty landing in the preceding 90 days. This requirement can be 

completed as an “enthusiast PIC” in order to meet such “commercial PIC requirements”.

31. Operations shall occur during daytime VFR Meteorological Conditions; flights under Special 

Visual Flight Rules ("SVFR") shall not be conducted.

32. The UA shall remain clear and yield the right of way to all other manned operations and activities 

at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang 

gliders, etc.).

33. GEO-UAS Operations under Instrument Flight Rules, at night, or beyond VLOS are prohibited.

34. The GEO-UAUs will not be operated from an elevated platform or moving device or vehicle.

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

GEO-UAS will comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory

authority, by its terms, includes exempting civil aircraft, as the term is defined under § 40101 of the Act,

including GEO-UASs, from its safety regulations and minimum standards when the Administrator decides a

requested exemption is in the public interest.

3 GEOSpec 3D seeks an exemption from several interrelated 

provisions of Title 14 of the Code of Federal Regulations ("14 C.F.R") Parts 21, 45, 61 and 91 for purposes 

of conducting the requested operations using a GEO-UAS. Listed below are: (1) the specific sections of 14 

C.F.R for which exemption is sought, and (2) the operating procedures and safeguards that Petitioner has 

established which will ensure a level of safety better than or equal to the rules from which exemption is 

sought.

4

3

49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702 - 44716).

4

14 C.F.R § 11.81(e), which requires a petition for exemption to include:

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 you seek exemption.
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UNMANNED AIRCRAFT SYSTEM

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the

Reform Act that the GEO-UAS selected provides an equivalent level of safety when compared to aircraft 

normally used for the same application. These criteria are met, and therefore no exemption is needed.

5 If, 

however, the FAA determines that there are some characteristics of the chosen GEO-UAS that fail to meet

the requirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety

GEOSpec 3D use of GEO-UAS is safe when taking into account their size, weight, speed, and

operational capability. As set forth in the description of proposed operations in Section IV (A), the

GEO-UAS weighs less than 55 pounds, including payload and will not be flown at a ground speed in 

excess of 50 knots. GEO-UAS is also equipped with safety features that will allow Petitioner to 

operate the GEO-UAS safely after experience certain in-flight contingencies or failures.

6 7

Additionally, the GEO-UAS carry neither pilots nor passengers, carry no explosive materials or 

flammable liquid fuels, and operate exclusively within the parameters stated in GEOSpec 3D

Operations Manuals.

5

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pgs. 13-14, 22).

6

See e.g., Grant of Exemption No. 11184 to Low Country RC, Corp. (FAA-2014-0803 at pg. 3): 

"The [GEO-UAS] has the capability to operate safely after experiencing certain in-flight

contingencies or failures and uses an auto-pilot system to maintain GEO-UAS stability and control.

The GEO-UAS is also able to respond to a loss of global positioning system (GPS) or a lost-link

event with a pre-coordinated, predictable, automated flight maneuver, and manual flight control

functionality as a backup. These safety features provide an equivalent level of safety compared to a

manned aircraft performing a similar operation."

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

"The GEO-UAS can be operated entirely by a touch-screen, map-based interface. This means the

operator only needs to command the system where to go, and the system does all the flying for the 

operator. The GEO-UAS can be operated in both semi and fully autonomousflight modes. In addition,

the GEO-UAS comes with pre-programmed no fly zones the GEO-UAS cannot enter areas deemed

unsafe or unnecessary to fly over. The petitioner states further that the GEO-UAS has built-in

intelligent fault handling which allowsthe GEO-UAS to detect a system fault while in the air and

automatically fly back to its takeoff location and land. Faults that can be detected include: loss of

communication; exceeding pre-set wind thresholds; and low battery levels.
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Operations conducted under this exemption will be closely controlled and monitored by the operator

and will be conducted in compliance with local public safety requirements, to provide security for the area of 

operation. GEOSpec 3D will also provide the FAA with advance notice of all operations via NOTAMs as

required by the applicable COA. In all cases, operation of the GEO-UAS under the proposed conditions will

be at least as safe as, or safer than, conventional rotorcraft operating with an airworthiness certificate.

Lastly, the GEO-UASs do not need a means to communicate with other aircraft or ATC, because 

those capabilities will be possessed by the PIC and Observer, who are not onboard the GEO-UAS.

8 In

addition, no sense-and-avoid technology is necessary for the GEO-UASs because they will be operated at all 

times in VFR conditions and within VLOS of the PIC and Operator.

9

 B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of

normal category rotorcraft. To the extent that GEOSpec 3D 's small GEO-UASs would otherwise

require certification under Part 27, Petitioner seeks an exemption from Part 27's airworthiness 

standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart 

H, supra.

{continued from previous page}

7

See e.g., Grant of Exemption No. 11184 to VDOS Global, LLC. (FAA-2014-0382 at pgs. 4-5): 

All flight operations are global positioning system (GPS) controlled, making the system easy to

navigate. At any point if the operator is not explicitly commanding the system to move, the system

automatically holds its GPS position. The flight control system employs not only GPS positioning but

a variety of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure

stability so long as wind thresholds are not exceeded. Also a flight termination link – to prevent a 'fly

away' or other potentially dangerous situation – is available to the operator."

8

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at pg. 13).

9

Id. 
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C. 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a): Aircraft Marking and Identification Requirements

GEOSpec 3D seeks an exemption from the aircraft marking and identification requirements contained 

in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a).

● 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking and Placard requirements, provides that:

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in 

accordance with Part 45 of this chapter.

● 14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or

"provisional," as applicable.

● 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of

the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was 

warranted provided that the aircraft "have identification (N-Number) markings in accordance with 14 C.F.R 

Part 45, Subpart C if the markings are as large as practicable."

10

Equivalent Level of Safety

All GEO-UAS flown by GEOSpec 3D will bear N-number markings that are as large as practicable in 

accordance with 14 C.F.R. Part 45, Subpart C.

11

10

FAA Docket No. FAA-2014-0352.

11

See, e.g., FAA Docket No. FAA-2014-0352, at 14. 
U.S. Department of Transportation

Aug 15th, 2015

Page 14

D. 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance

Inspections

GEOSpec 3D seeks an exemption from the maintenance inspection requirements contained in

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance

and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each 

owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections ...have discrepancies repaired as prescribed in part 43 of this chapter"). 

An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with 

an airworthiness certificate, which the GEO-UAS to be operated under this grant of exemption will not have.

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections will be performed 

in accordance with the Manufacturer's Manual and any required manufacturer Safety or Service Bulletins. 

Further, as required by GEOSpec 3D Operations Manuals, the PIC will conduct a pre-flight inspection of the 

GEO-UAS and all associated equipment to account for all discrepancies and/or inoperable components. 

Maintenance will be performed and verified to address any conditions potentially affecting safe operation of

the GEO-UAS and no flights will occur unless, and until, all flight critical components of the GEO-UAS

have been found to be airworthy and in a condition safe for operation. A functional test flight will be 

conducted following the replacement of any flight-critical components. As required by GEOSpec 3D

Operations Manuals, the PIC who conducts the functional test flight will make an entry in the GEO-UAS

aircraft records of the flight.

GEOSpec 3D Operations Manual also includes requirements to follow the manufacturer’s GEO-UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements for the

following applicable components: powertrain system (powerplant), propellers, avionics and control surfaces 

(including ailerons/elevons), structures & airframe, camera system, electrical systems (including batteries),

ground control station, hazard accessories, and spare parts. Further, GEOSpec 3D Operations Manuals also 

includes procedures to document and maintain a record of the GEO-UAS maintenance, preventative 

maintenance, alterations, status of replacement /overhaul component parts, and the total time in service of the

GEO-UASs used under this Grant of Exemption. As a whole, the maintenance and inspection procedures 

required in GEOSpec 3D Operations Manuals ensure that an equivalent or higher level of safety will be 

achieved.

 
U.S. Department of Transportation

Aug 15th, 2015

Page 15

PILOT-IN-COMMAND OF THE GEO-UAS

E. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations

GEOSpec 3D seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders 

from flying aircraft for compensation or hire, and would also require a second class medical certificate. The

purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the 

PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for

hire. In this case, while the GEO-UASs will be operated as part of a commercial operation, it carries neither

passengers nor cargo. In the Grant of Exemption to Astraeus Aerial

12, the FAA determined that the unique 

characteristics of GEO-UAS operation outside of controlled airspace did not warrant the addition cost and 

restrictions attendant with requiring a the PIC to have a Commercial Pilot Certificate and Class II Medical 

Certificate. The fulfillment of the additional requirements for a private pilot to become qualified as a 

commercial pilot would not lead to any additional safety benefits when GEO-UAS operations are involved.

Equivalent Level of Safety

The restrictions GEOSpec 3D has placed on its GEO-UAS operations meet or exceed the restrictions 

similarly imposed on Astraeus Aerial. GEOSpec 3D will operate on private property away from persons and 

property not involved in the operation. GEOSpec 3D will also obtain an ATO issued COA prior to 

conducting any operations under this Grant of Exemption. All operations will be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements. A NOTAM will also be issued as required by the applicable COA.

In addition to these flight restrictions, GEOSpec 3D will further ensure safe operation by requiring

that any PIC be thoroughly versed not only in airspace and communication issues pertaining to all aircraft 

operators but also in the unique aspects of GEO-UAS flight. As set forth in the Operations Manuals, pilots 

will have experience not only in GEO-UAS operations generally but have logged flight time in the specific 

make and model used for the operations before they are permitted to participate in commercial flights on

behalf of GEOSpec 3D. The pilot qualification, training, and currency requirements in the Operations 

Manuals ensure that GEOSpec 3D pilots are competent and proficient in the GEO-UAS they are operating. 

GEOSpec 3Dtraining and qualification requirements are consistent with those contained in prior FAA

Section 333 Grants of Exemption, and will provide a higher level of competency and proficiency for its pilots 

and will ensure at least an equivalent level of safety.

12

Exemption No. 11062 (FAA Docket No. FAA-2014-0352).
U.S. Department of Transportation

Aug 15th, 2015

Page 16

OPERATING PARAMETERS OF THE GEO-UAS

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

Although there will be no airworthiness certificate issued for the GEO-UASs, GEOSpec 3D seeks 

an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in airworthy condition to be

operated. The FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the extent that the 

requirements of Part 21 are waived or found inapplicable.

13 Accordingly, Petitioner requests that the 

requirements for § 91.7(a) be treated in accordance with Section V (A), supra.

G. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft and 14

C.F.R. § 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Title 14 C.F.R. § 91.9(b)(2) and § 91.203(a) and (b) require the operator to carry airworthiness

documents and other aircraft manuals onboard the aircraft. Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S.-registered civil aircraft –

(2) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this chapter, unless 

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

manual material, markings, and placards, or any combination thereof.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the

following:

(1) An appropriate and current airworthiness certificate...

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph

(a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or

cockpit entrance so that it is legible to passengers or crew.

13

See id. at 13-14, 22 
U.S. Department of Transportation

Aug 15th, 2015

Page 17

Given the small size and configuration of the GEO-UASs, it would be impossible to keep 

airworthiness documents and other aircraft manuals on board the GEO-UAS because there is simply no 

room and the GEO-UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by Dean E. 

Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) and 91.203(a) and 

(b) is met if the pilot of the unmanned aircraft has access to the GEO-UAS flight manual, registration 

certificate, and other required documents from the ground control station from which he or she is operating

the aircraft.

14 As this FAA Office of Chief Counsel Opinion clarifies, the intent of the rule is to ensure the 

pilot has access to these key documents during flight. Therefore, an equivalent level of safety will be

achieved by ensuring that the pilot has access to the documents at the ground control station from which he

or she is piloting the GEO-UAS.

H. 14 C.F.R. § 91.103: Preflight Action

GEOSpec 3D seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become 

familiar with specific information before each flight, including information contained in the FAA-approved

Flight Manual on board the aircraft. While the PIC will be familiar with all information necessary to safely

conduct the flight, an exemption is requested to the extent that an FAA-approved Flight Manual is required.

Equivalent Level of Safety

An equivalent level of safety will be provided by following the GEOSpec 3D Operations Manuals 

and the Manufacturer's Manual. The PIC will perform a series of checklists designed to identify any

defects or inoperable components in accordance with the GEOSpec 3D Operations Manuals, including 

checklists covering Pre-Flight, Launch, Landing, and Post-Flight procedures. The PIC will also be required 

to review weather, flight requirements, battery charge, landing and takeoff distance, GEO-UAS

performance data, and contingency landing areas—before initiation of flight. GEOSpec 3D Operations

Manuals and the Manufacturer's Manual will be kept at the ground control station and will be accessible to 

the PIC at all times while operating the GEO-UAS.

I. 14 C.F.R. § 91.109(a): Flight Instruction

14 Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and 

Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014); see also Docket No. FAA2014-0352 at 16-18.
U.S. Department of Transportation

Aug 15th, 2015

Page 18

GEOSpec 3D seeks an exemption from 14 C.F.R. § 91.109(a), which provides in pertinent part that 

"[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." GEO-UASs and remotely piloted 

aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished 

through the use of a device that communicates with the aircraft via radio communications. Accordingly, an 

exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a).

Equivalent Level of Safety

Given the size and speed of the GEO-UASs that GEOSpec 3D intends to use, an equivalent level of 

safe training can still be performed without dual controls because no pilot or passengers are aboard the GEOUAS, and as required by the GEOSpec 3D Operations Manuals, all persons will be a safe distance away in 

the event that the GEO-UAS experiences any difficulties during flight instruction. Moreover, as required by

the GEOSpec 3D Operations Manuals, all flight training will be conducted in controlled and sterile 

environment. As a whole, the safety procedures provided for in GEOSpec 3D Operations Manuals ensure

that the proposed GEO-UAS operations provide an equivalent or higher level of safety than that provided by

the flight instruction regulations.

J. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes

GEOSpec 3D requests an exemption from the minimum safe altitude requirements of 14 C.F.R. § 

91.119(c).

15 Section 91.119 prescribes the minimum safe altitudes under which aircraft may not operate, 

including 500 feet above the surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a helicopter to operate at less than those

minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided 

that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for

helicopters by the FAA."

An exemption is required because the proposed GEO-UAS operations will normally need to occur

below 400 feet AGL. In circumstances where the GEO-UAS is used to inspect a structure whose height 

exceeds 400 feet AGL, the GEO-UAS will not be operated more than 100 feet above the highest point on the 

structure, and within 50 feet horizontally of the structure. Additionally, due the nature of the proposed 

operations, the Pilot and/or Observers(s) may need to be less than 500 feet away from the GEO-UAS.

15Relief from § 91.119(a) will not be necessary because Petitioner will be able to perform an emergency

landing without undue hazard to persons or property on the ground in the event of a failure. Petitioner's 

proposed GEO-UAS operations will not occur over congested areas, and therefore an exemption from § 

91.119(b) will not be necessary. See e.g., Grant of Exemption No. 11157 to Slug wear, Inc., dba Like on a

tree Aerial (FAA-2014-0534 at 15)
U.S. Department of Transportation

Aug 15th, 2015

Page 19

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum weights proposed 

herein, and given the lack of flammable fuel with the GEO-UASs, any risk associated with these operations is 

far less than those that presently exist with conventional aircraft. An equivalent level of safety will be

achieved given the size, weight, and speed of the GEO-UASs, as well the controlled location where the

operations will occur. In order to avoid any risk to manned aircraft, flight operations will be restricted to 400 

feet AGL or below, or when inspecting a structure whose height exceeds 400 feet AGL, within 100 feet

above the highest point on that structure and 50 feet horizontally of the structure.

As set forth in the Operations Manuals, the GEO-UASs will be operated in a restricted area, and all

flights will be operated at a lateral distance of at least 500 feet from any nonparticipating persons, unless that 

person is in a position where he or she is shielded from the GEO-UAS and any possible debris resulting from 

GEO-UAS failure. As required by the Operations Manuals, flights will be terminated if a nonparticipating

person within 500 feet of the GEO-UAS leaves a shielded position. Further, GEO-UAS operations will occur

at least 500 feet away from vehicles or structures unless the property owner/controller has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to those objects and, operations near 

the PIC or Observer will not present an undue hazard per § 91.119(a). Adherence to these restrictions in the 

elevation of the departure airport or barometric pressure. An exemption is required to the extent that the 

GEO-UASs do not have a barometric altimeter, but rather a GPS altitude read out. GEOSpec 3DOperations 

Manuals will ensure operations can be conducted without compromising safety.

16

K. 14 C.F.R. § 91.121: Altimeter Settings

GEOSpec 3D seeks an exemption from 14 C.F.R. § 91.121, which requires a person operating an 

aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of

the departure airport or barometric pressure An exemption is required to the extent that the GEO-UASs do

not have a barometric altimeter, but rather a GPS altitude read out.

16

See e.g., Grant of Exemption No. 11138 to Douglas Trudeau (FAA-2014-0481 at 19):

"If barriers or structures are present that can sufficiently protect nonparticipating persons from the

UA or debris in the event of an accident, then the UA may operate closer than 500 feet to persons

afforded such protection. The operator must also 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. When considering how to 

immediately cease operations, the primary concern is the safety of those nonparticipating persons. In

addition, the FAA finds that operations may be conducted closer than 500 feet to vessels, vehicles

and structures when the owner/controller of any such vessels, vehicles orstructures grants permission

for the operation and the PIC makes a safety assessment of the risk of operating closer to those 

objects and determines that it does not present an undue hazard.”
U.S. Department of Transportation

Aug 15th, 2015

Page 20

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety to the requirements of 14 C.F.R. §

91.121 can be achieved in circumstances where: (1) the GEO-UASs will be operated below 400 feet AGL

or 

below

17

, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator 

at a ground-based on-screen display and, (4) where prior to each flight, a zero altitude initiation point is 

established for the PIC to confirm accuracy of the onboard GPS.

18

The GEO-UASs that GEOSpec 3D intends to use for the proposed operations will meet all these 

operational characteristics. Moreover, as required by GEOSpec 3D Operations Manuals, the PIC will be

required to calibrate the aircraft's GPS compass prior to each flight operation. Like prior FAA Section 333 

Grants of Exemption, the GEO-UASs GEOSpec 3D intends to use, and the safety mitigation procedures 

contained in the Operations Manuals, both ensure that an equivalent level of safety will be achieved, and a

Grant of Exemption to the requirements of § 191.121 is therefore appropriate.

L. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

GEOSpec 3D requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR

conditions. Section 91.151 states: 

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

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

assuming normal cruising speed –

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

or

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

Here, the technological limitations on GEO-UAS battery power means that no meaningful flight 

operations can be conducted while still maintaining a 30-minute battery reserve. An exemption from the

fuel requirements of 14 C.F.R. § 91.151(a) is therefore required.

17

If the height of the structure being inspected exceeds 400 feet AGL, the GEO-UAS will not be operated 

more than 100 feet above the highest point on the structure.

18

See Grant of Exemption No. 11062 to Astraeus Aerial (FAA-2014-0352 at 21).
U.S. Department of Transportation

Aug 15th, 2015

Page 21

Equivalent Level of Safety 

 In the Grant of Exemption to VDOS (Exemption No. 11112), the FAA determined that an 

equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a GEO-UAS flight unless (considering wind and forecast weather 

conditions) there was enough power to fly to the first intended point of landing and, assuming normal 

cruising speed, to fly after that for at least 10 minutes. 

In reaching this conclusion, the FAA considered that the GEO-UAS batteries for the GEO-UAS

provided provide approximately 20 minutes of powered flight (with payload) and provided battery level 

and battery time remaining in minutes and seconds to the PIC.19 The FAA also considered the fact that the 

GEO-UAS operating manual states: “start every flight with a fully charged battery in the aerial vehicle”, 

and that in the event that the GEO-UAS should run low on power, the PIC will be alerted and can land the 

GEO-UAS as soon as possible. Like the VDOS Grant of Exemption, GEOSpec 3D use of the DJI Phantom 

II & S900, combined with the requirements of Petitioner's Operations Manuals, ensure that an equivalent 

level of safety can be achieved. 

Similarly, in the Grant of Exemption to Alan Purwin (Exemption No. 11161), the FAA determined 

that an equivalent level of safety to the fuel requirements for flight in VFR conditions could be achieved by 

prohibiting the PIC from beginning a flight with the GEO-UAS unless (considering wind and forecast 

weather conditions), there was enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. GEOSpec 3D will adhere to this limitation for GEOUAS flights. 

The GEO-UAS includes a low battery warning system and the amount of battery reserve power 

remaining is transmitted to the PIC via telemetric data feed, which downlinks from the GEO-UAS to a 

ground-based-on-screen display.20 As required by GEOSpec 3D Operations Manuals, the PIC will 

promptly fly the GEO-UAS back to the home launch location or pre-determined abort location where the 

GEO-UAS may safely land, while still maintaining a minimum of 25% reserve battery power. GEOSpec 

3D submits that the procedures requiring flights to be safely terminated once the batteries fall below 25% 

capacity, combined with the requirement that flights only be conducted within a secure, isolated area, using 

a GEO-UAS weighting less than 25 pounds, and within VLOS of the PIC and Observer(s), ensure that the 

proposed operation will provide an equivalent or higher level of safety to that provided by the regulations 

from which exemption is sought. 

19 Grant of Exemption No. 11112 to VDOS Global, LLC (FAA-2014-0382 at 10). 

20 The GEO-UAS ground control station displays, the GEO-UASs position, navigation route, tail number, 

altitude, heading, north seeking arrow, range to targets, calculated target position, date/time, and sensor 

heading and orientation relative to the GEO-UAS. 
U.S. Department of Transportation

Aug 15th, 2015

Page 22

VI. DRUG AND ALCOHOL PROGRAM

GEOSpec 3D will have policies in place to ensure that no person may participate in GEO-UAS

flight operations if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

The public interest will be served by granting GEOSpec 3D Petition for Exemption. Congress has 

established a national policy that favors early integration of GEO-UAS into the NAS in controlled, safe 

working environments such as those proposed in this Petition. Granting this Petition for Exemption helps 

fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act—the FAA Administrator's

assessment of whether certain GEO-UAS may operate safely in the NAS before completion of the 

statutorily required rulemaking.

The proposed GEO-UAS operations in this Petition for Exemption significantly improve safety and 

reduce risk harm or serious injury or death to inspecting engineers. Traditional methods of inspecting 

and/or monitoring industrial and utility power-generation facilities and infrastructure requires inspectors to 

climb towers or otherwise perform elevated work, which exposes them to the risk of dangerous falls. 

Inspectors are often exposed to hazardous chemicals or oxygen-deficient atmospheres, burns from steam 

electrical or from hot equipment, and other mechanical hazards associated with industrial and utility sites 

facilities. The use of small GEO-UAS can eliminate these hazards and is ultimately a much safer method of 

performing these types of inspections services. 

The use of small GEO-UASs also enhances safety and reduces risk because, unlike manned aircraft 

weighing thousands of pounds, carrying crew in addition to flammable fuel, the GEO-UASs carry no 

passengers or crew. Further, in the unlikely event of an accident, GEOSpec 3D small battery powered 

GEO-UAS presents significantly less danger to persons on the ground when compared to operations by 

conventional manned aircraft.21 As Petitioner's GEO-UASs are battery powered, the public will also 

benefit from the reduction of public utility down time because of the lack of staff that can perform such 

dangerous inspections and the a reduction in harmful emissions associated with conventional aircraft 

performing in the same functions proposed herein. Lastly, as recognized by the FAA in prior Section 333 

Grants of Exemption to filmmakers, GEO-UASs provide an additional tool for the aerial filming industry, 

adding a greater degree of flexibility, which supplements the current capabilities offered by manned 

aircraft.22

21 See Grant of Exemption No. 11158 to Team 5, LLC (FAA-2014-0783 at 12): 

"Manned helicopters conducting aerial inspection can weigh 6,000 pounds or more and are operated by an 

onboard pilot, in addition to other onboard crewmembers, as necessary. The petitioner’s UAs will weigh 

less than 55 pounds with no onboard pilot or crew. The pilot and crew will be remotely located from the 

aircraft. The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk to an onboard pilot 

and crew during an accident is eliminated with the use of a UA for aerial inspection operations." 
U.S. Department of Transportation

Aug 15th, 2015

Page 23

VIII. PRIVACY 

All GEOSpec 3D GEO-UAS operations will be conducted in accordance with applicable federal, 

state, or local laws regarding privacy. 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. 

IX. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL 

REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations: 

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.113; 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 

91.119(c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & 

(b).

The exemption will enhance safety by reducing risk to the general public and property owners from 

the substantial hazards associated with performing equivalent work and aerial inspection of public and 

private facilities, construction sites with conventional fixed-wing aircraft, rotorcraft, or other methods.

X. CONCLUSION

GEOSpec 3D Petition for Exemption satisfies the criteria articulated in Section 333 of the Reform 

Act of 2012 including weight, speed, operating capabilities, proximity to airports and populated areas, 

operation within VLOS and national security. The proposed GEO-UAS operations will benefit the public as 

a whole by improving safety and reducing risk by alleviating human exposure to danger. In consideration 

of the foregoing, this Petition for Exemption provides the FAA with more than adequate justification for 

granting the requested exemptions allowing GEOSpec 3D to use small GEO-UAS for controlled flights for 

high level aerial facilities and construction site inspection.

22 See e.g., Grant of Exemption No. 11178 to Picture Factory, Inc. (FAA-2014-0794 at 18).
U.S. Department of Transportation

Aug 15th, 2015

Page 24

We thank you for your prompt consideration of our requested exemptions. 

Should you have any questions, or if you need any additional information to support the requested 

exemptions, please contact the undersigned at:

GEOSpec 3D, LLC.

Phone: 512-535-8007

Email: Jason.Orton777@Gmail.com

(The following attached items contain proprietary and commercial information exempt from disclosure 

under the Freedom of Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant 

to 14 C.F.R. § 11.35(b)). 

Attachments: 

1. General Operations Manual

2. PIC Operating Manual

3. Company Protocols

4. Location Protocols 

5. Flight Communications Protocols

6. Departing Location Protocols

7. Transmitter Protocols

8. Preflight Checklist

9. Post Flight Checklist

10. Equipment Checklist

11. UAS Manufacturer’s Manuals

a. User Manuals

b. UAS Maintenance Manuals