1

February 6, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Keystone Aerial Surveys, Inc. Petition for Section 333 Exemption for Altavian Nova F6500

Dear Sir,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. Part 11, 

Keystone Aerial Surveys, Inc. (Keystone) is petitioning the Federal Aviation Administration (FAA) for an 

exemption from the Federal Aviation Regulations (FARs) requested below concerning small unmanned 

aerial systems (UAS). Section 333 of the FMRA promotes UAS integration into the national airspace by 

granting the FAA authority to allow for the safe operation of certain UAS within the national airspace.

Keystone specializes in providing quality aerial surveys. Keystone has flown millions of survey miles 

throughout the United States on projects with varied specifications. We have four locations:

Philadelphia, PA (headquarters); Tyler, TX; Tucson, AZ; and Los Angeles, CA. Our Flight Department has 

considerable experience collecting airborne imagery at high and low altitudes in several formats 

including digital, film and LiDAR. Keystone also collects and processes both Airborne GPS (ABGPS) and 

Inertial Measurement Unit (IMU) data. 

Keystone currently operates twenty U.S.-registered manned aircraft, thirteen metric film camera 

systems, four large format digital sensors and one LiDAR system, and employs flight crews consisting of 

FAA-licensed commercial pilots, camera operators, four full time licensed aircraft mechanics and a fully 

equipped and staffed photo lab and IT Department for extensive post processing support. Six of 

Keystone’s employees are ASPRS Certified Photogrammetrists. With this significant capability and over 

50 years of aerial survey knowledge and the experience gained through managing and acquiring over 

350 individual large-scale digital projects for various clients throughout the United States, Keystone is 

uniquely positioned to acquire aerial imagery collection projects with various requirements while 

ensuring the timely delivery of the best possible product.

As shown below, Keystone proposes to operate small UAS subject to restrictions and conditions that will 

ensure an equivalent level of safety and that are at least as stringent as those that FAA has found to be 

acceptable in its most recent grants of petitions under Section 333, including Exemption Nos. 11150 and 

11153 issued on January 23, 2015. Further, this petition raises no national security or privacy concerns 
2

for the reasons discussed below. Keystone therefore respectfully submits that prompt grant of this 

petition is warranted. 

As a data provider, Keystone will not be analyzing or interpreting data; rather, Keystone exists to provide 

Remote Sensing in a safe and effective manner for multiple industries and governmental uses. For this 

reason, Keystone will use, in addition to other aircraft, the Altavian Nova F6500 (also known as the Nova 

Block III) with the metric camera sensor package. This aircraft is familiar to the FAA and has been 

approved for use in Exemption Nos. 11111 and 11114 issued on December 10, 2014. The detailed 

specifications of the aircraft are listed in a section below.

Keystone will use licensed pilots and visual observers (VOs) for all of its UAS operations. All pilots and 

VOs will receive factory training and flight hours in accordance with manufacturer and Keystone 

operational manuals before approval to fly is given. Recurrent training for UAS pilots and VOs will be 

outlined and implemented in a manner similar to what Keystone requires of its manned aircraft pilots, 

details of which appear in the Keystone Flight Operations Manual.1

Keystone is requesting this exemption in order to provide services for many industries, including but not 

limited to:

1. Mapping – High resolution imagery will be used for small area mapping in situations where UAS 

acquisition is safer, more cost effective or faster than manned aircraft (as in disaster 

response/assessment, etc.)

2. Government Agencies – Federal, State and Local (Local governments with limited budgets will 

be better able to afford UAS surveys as opposed to manned flights)

3. Engineering – Mining, waste disposal, pipelines, etc.

4. Insurance – Claim assessment

5. Geographic Information Systems – Populating data for analysis, including precision agriculture

6. Solar panel installation, maintenance and assessment

7. Wireless installation and maintenance

Keystone is requesting to use the UAS in remote or rural locations in states where it currently has bases 

(PA, CA, AZ, and TX) and contiguous states where Keystone often operates out of these bases (NJ, NY, 

MD, DE, OK, NM, and NV). These locations will fall outside of populated areas when plotted on VFR 

Sectional Aeronautical Charts, will not be within five (5) miles of any airport or helipad (unless FAA has 

approved such operations and Keystone has a written agreement with the airport/helipad manager),

not be within 100 meters of federal or state roads having more than two lanes and not within 50 meters 

of all paved state roads having two lanes or less. Keystone is requesting permission to fly over state 

owned/maintained unpaved or unimproved roads in anticipation of meeting the known governmental 

need to cost effectively assess these types of rural roads.

Keystone’s initial work will take place near its corporate headquarters in Philadelphia, PA with programs 

at its other offices in the southwest and west to follow. The plan will be to develop customer awareness 

and projects in the states closest to Philadelphia, further refining procedures and operational details. 

 

1 Keystone is submitting its Flight Operations Manual, the Altavian Nova F6500 Maintenance and Operator 

Manuals and the Altavian Nova Family Operations Manual confidentially pursuant to 14 CFR Section 11.35(b). The 

Manual contains confidential, proprietary and commercially sensitive information that has not been made 

available to the public and that is protected under the Freedom of Information Act, 5 U.S.C. § 552, et seq. 
3

When Keystone is confident in its operations, has an experienced workforce and demand in other 

regions, the other offices will begin operations. This process is expected to take six months from 

receiving approval of the exemption.

Petitioner Name and Address:

Keystone Aerial Surveys, Inc.

Northeast Philadelphia Airport

9800 Ashton Road

PO Box 20159

Philadelphia, PA 19114

(215) 677-3119

dday@kasurveys.com

Exemption Requested:

Keystone Aerial Surveys, Inc. is requesting this waiver as it applies to the following FARs:

 14 CFR Section 61.113 (a) and (b): Private pilot privileges and limitations

 14 CFR Section 91.7: Civil aircraft airworthiness

 14 CFR Section 91.119: Minimum altitude requirements

 14 CFR Section 91.121: Altimeter requirements

 14 CFR Section 91.151: Fuel requirements

 14 CFR Section 91.405: Maintenance requirements

 14 CFR Section 91.407: Maintenance requirements

 14 CFR Section 91.409: Inspection frequency

 14 CFR Section 91.417: Maintenance records

Keystone’s History

Keystone Aerial Surveys, Inc., a United States based flyer, and a wholly owned subsidiary of PASCO 

Corp., has been safely performing aerial data acquisition throughout the US for over 50 years. Keystone 

takes safety and professionalism seriously in its role as a part 91 operator. Keystone has long operated 

in compliance with the rules governing use of the National Airspace. Keystone has worked successfully 

for both public and private entities in some of the most congested airspace in the United States 

(including New York, Philadelphia, Atlanta, Dallas, Los Angeles, and Washington, D.C.). Keystone has 

worked with military bases to obtain access to no-fly zones in support of USGS, USDA and other 

government agencies.

Keystone’s fleet of 20 aircraft consists of a mix of single and twin engine Cessnas and several other fixed 

wing aircraft suited to the aerial acquisition industry. A staff of nearly twenty full time commercial pilots 

are employed across Keystone’s four offices, while five full time maintenance personnel are dedicated 

to the care and safety of the aircraft. Additionally, Keystone has worked extensively with the 

Philadelphia Flight Standards District Office for aircraft modifications for survey missions.
4

Summary of operations

1. All flights will be conducted in accordance with Keystone’s Flight Operations Manual (FOM) and 

the manufacturer operations manual(s) following Visual Flight Rules (VFR) during Visual 

Meteorological Conditions (VMC).

2. The UAS with payload will weigh less than 55 pounds.

3. The UAS pilot must hold at least an FAA private pilot’s license with at least a third class medical 

certificate.

4. All flights will include a Pilot in Command (PIC) and Visual Observer (VO). Flights will be 

operated within line of sight of the PIC and VO. The PIC and VO will be able to communicate 

verbally at all times.

5. Maximum flight time will be less than 80 minutes per the manufacturer’s recommendation. 

6. Airspeed will not exceed 60 knots.

7. Flights will be operated at an altitude of 400 feet AGL or less and more than 100 feet above any 

building or structure to be imaged or inspected.

8. All flights will be conducted as to maintain a lateral distance of at least 500 feet from any 

structures, buildings, vehicles, vessels or persons not associated with or given consent to the 

operation, unless barriers or structures are present that sufficiently protect nonparticipating 

persons. Flights will be conducted at least 100 meters from roads with more than two lanes 

and at least 50 meters from all other paved roads. 

9. The Pilot will have manufacturer training and flight hours with the Nova F6500 in accordance 

with the Keystone FOM and the manufacturer’s requirements. Specifically, minimums of 25 UAS 

flight hours, 10 hours with the Nova F6500 or similar type (fixed wing UAS), 5 hours with the 

Nova F6500 and 3 takeoffs and landings with the F6500 in the last 90 days will be required.

10. The VO will have training on UAS operations and manufacturer training on the Nova F6500.

11. All required permissions and notifications to federal, state and local governments, Air Traffic 

Control and private land holders will be made/obtained prior to any flight.

12. In accordance to the Keystone FOM, alternate landing areas and contingency plans will be in 

place before any UAS flight is attempted.

13. The UAS will not be flown at night or when weather conditions may prevent a visual observation 

of the vehicle throughout the duration of the flight.

14. All flights will be performed with the safety and privacy of those not involved or aware of the 

flight as a key concern. The UA will remain clear and yield to all manned aircraft.

15. If GPS connectivity is lost but link remains, the PIC will manually return the aircraft to one of the 

pre-determined landing zones or perform an immediate emergency landing as per the Keystone

FOM.

16. In the unlikely event of a lost link/communication loss, the PIC will notify ATC immediately and 

the VO will maintain visual of the UAS and document its location. According to manufacturer 

and Keystone protocols, prior to flight, the F6500 is preprogrammed with an automated landing 

location. The UAS will perform an automatic landing at the location within the mission site 

should a loss of link occur.

17. Prior to each flight, the PIC will inspect the UAS to confirm that it meets manufacturer 

specification for safe flight. After a maintenance event involving a critical component of the UA, 

a test flight will be performed and logged in the aircraft maintenance logs.
5

18. Keystone will follow all manufacturer maintenance and inspection procedures, schedules and 

documents for the UA and log each event in the aircraft maintenance logs in accordance with 

the Keystone FOM in similar manner to manned aircraft.

Aircraft to be Used

The Altavian Nova F6500 Aircraft is an all-electric drone that provides precision 3D mapping and realtime thermal infrared and high definition video capabilities. The system deploys quickly in nearly every 

environment due to its light weight and hand-launchable design. The Nova F6500 has been previously 

approved for use in the national airspace, has a 14 CFR 91.215 compatible transponder and has a proven 

safety record. 

The F6500 can be landed in water for safety concerns and provides a generally stable platform for aerial 

sensing operations. The Altavian Nova F6500 is well suited for large area collections at higher accuracies 

due to its long endurance and quality or interchangeable payloads.

Specifications include:

 Wing Span: 108”

 Length: 67”

 Weight 15lbs without payload and <20lbs with payload

 Top speed: 60 knots

 Cruise Speed: 30 knots

 Endurance: 1.5 hours

Extent of relief 

Keystone seeks an exemption from several and often interrelated provisions of 14 CFR Part 91 in 

conjunction with the operations it is requesting to undertake as part of the UAS exemption. The 

following list details the exemptions requested and the procedures that will ensure an equivalent level 

of safety to the public and the national airspace. FAA has granted similar exemptions to those 

requested below in, for example, Exemption Nos. 11136, 11138, 11150 and 11153.

A. 14 CFR Section 61.113 (a) and (b)

Section 61.113 (a) prohibits a pilot from operating an aircraft for hire or compensation with a 

private pilot’s license. Part (b) allows a private pilot to fly an aircraft for hire if the flight is 

incidental to the business; in as much as Keystone’s primary business is data acquisition during 

flight, an exemption from this section is also necessary.

Equivalent Level of Safety

Because the UAS does not carry crew or persons, the operations proposed in this request can be 

carried out with appropriate safety by pilots with private licenses. While it is likely that many of the 

pilots flying Keystone UAS will be commercial pilots, the type of flying and safety measures expected

of the pilot and industry do not require this license. Additionally, all pilots will be under the 
6

supervision and training of commercial pilots, ensuring professionalism and safety in the airspace. 

Keystone also believes that the awareness of airspace restrictions, communication with ATC and

situational awareness concerns are satisfied by a private pilot’s license. The FAA itself, in Exemption 

No. 11066, concluded that private pilot licensing will ensure that the PIC has proper knowledge and 

training by comparing skills side by side. For these reasons, Keystone is certain that an equivalent 

level of safety will be maintained with this exemption.

B. 14 CFR Section 91.7(a): Civil aircraft airworthiness

Section 91.7(a) requires that no person may operate a civil aircraft unless it is in an airworthy 

condition. To the extent that this regulation would require an airworthiness certificate for the 

aircraft, Keystone requests an exemption. 

Equivalent Level of Safety

All UAS operated by Keystone will be under 55 pounds including payload and will operate in a 

defined area made known to local ATC. Furthermore, the vehicles Keystone will operate do not 

carry personnel, explosive materials or flammable liquid fuels or other potentially hazardous 

materials. The vehicles to be used will be maintained to the strict tolerances of Keystone’s 

maintenance staff and the guidelines set out in the operations manuals of the manufacturer and 

Keystone’s FOM. The NOVA series UAS from Altavian has been approved for use in two previous 

Section 333 exemptions (Exemption # 11111 and 11114) and many thousands of successful flight 

hours have been logged with this vehicle. This UAS, piloted by Keystone’s pilots, does not represent 

a risk to the national airspace or the public. 

C. 14 CFR Section 91.119(c): Minimum altitude requirements

Petitioner requests an exemption from the minimum safe altitude requirements specified in 14 CFR 

91.119(c). The altitude required by this section is 500 feet above the surface and persons, vehicles, 

etc. However, section 91.119(d) allows for a helicopter to operate at less than those minimum 

altitudes when it can be operated safely and Keystone has received exemptions to fly fixed wing 

aircraft below 500 feet over uninhabited areas.

Keystone plans to operate the UAS at 400 feet AGL or below (but not less than 100 feet above 

structures, buildings, vehicles, etc.) in order to properly collect survey data and to avoid entering the 

national airspace at an altitude that could possibly conflict with manned aircraft.

Equivalent Level of Safety

As explained in this document, the manufacturer flight manual and Keystone’s FOM, every 

precaution will be taken to assure that the UAS is operating safely with existing air traffic and poses 

no risk to ground assets and persons.
7

D. 14 CFR Section 91.121: Altimeter requirements

This section of Title 14 requires that the pilot of the aircraft use an altimeter on board the aircraft to 

determine altitude. The altimeter must be set based on the barometric pressure of the departing 

airport and airports in route. Petitioner seeks an exemption from 14 CFR Part 91.121 as the aircraft 

does not use an altimeter for elevation determination, but a GPS receiver instead.

Equivalent Level of Safety

As part of the flight monitoring software of each UAS, the GPS altitude is displayed to the VO. As 

the VO is in communication with the PIC, any deviations from the pre-planned altitudes of the flight 

will be communicated by the VO and feedback will be given during manually controlled flight when 

altitude approaches 400 feet. Pre-flight checks will confirm the GPS altitude of the location of the 

flight compared to the flight plan to confirm the plan’s accuracy and make any necessary changes 

(including the abort of the mission).

E. 14 CFR Section 91.151: Fuel requirements

Petitioner requests exemption from 14 CFR Part 91.151 which 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”

The remaining section does not apply, as the UAS will not be flown at night. Since most UAS flights 

will be 45-60 minutes in duration, another method of determining safe flight limits must be 

considered.

Equivalent Level of Safety

Keystone will require that in order for the pilot to take off (initiate a survey), the battery charge 

displayed by the system must be a full charge (>97%) and the aircraft must end its survey such that 

the total flight time does not exceed 80 minutes, in accordance with the manufacturer’s 

recommendation. This will ensure that the UAS lands safely at one of the two designated landing 

areas before battery life becomes critical or unstable.

F. 14 CFR Section 91.405, 14 CFR Section 91.407, 14 CFR Section 91.409, 14 CFR Section 91.417: 

Maintenance Reporting and Maintenance Inspection frequency

Petitioner seeks an exemption from the above regulations and their references to 14 CFR Part 43. 

14 CFR 91.405(a) states that each owner or operator of an aircraft “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”. 

Since the UAS will not have an airworthiness certification, these regulations will not apply to these 
8

aircraft. Additionally, the nature of the vehicles is that of easily replaced parts and a much smaller 

amount of parts that can be replaced – making inspection schedules less fixed and field repairs 

possible.

Equivalent Level of Safety

Using the manufacturer’s operations manual, an inspection and preventative maintenance schedule 

will be created for the Nova F5600. Because the UAS is dismantled for storage and shipment after 

each flight, a thorough inspection will be performed after the reassembly of the vehicle and before 

each flight.

The maintenance will be overseen by Keystone’s Director of Unmanned Airborne Vehicle 

Maintenance (DUAVM) who will ensure that the inspections and preventative maintenance are 

performed and logged and signed in the UAS log book. It is Keystone’s intention to keep 

maintenance logs for each of its UAS in a similar manner as its manned aircraft and to make these 

available to FAA inspection at any time. The DUAVM will ensure that any PIC or VO is able to 

perform field repairs and replacements as necessary to the level of quality Keystone expects from its 

manned aircraft maintenance personnel. All field repairs and replacements will be correctly logged

and signed on site by the PIC.

Public Interest

Granting Keystone this waiver is in the public interest for several reasons. The work that Keystone 

performs on a daily basis from its manned aircraft is largely for use in mapping and geographic 

information systems (GIS) activities that add to the public’s benefit including flood plain mapping, 

disaster response and planning, street maps, crop damage, environmental studies, prevention of 

insurance and tax fraud through inventory and more. This will continue to be the case with data 

collected via UAS, with the hope that more uses can be developed by Keystone’s clients with this new 

technology.

Additionally, because Keystone employs professional pilots with the purpose of safe and effective data 

collection, Keystone will perform safe and efficient surveys for the many and various industries that it 

currently supports. This will decrease the need for manned aircraft in the air and thus reduce pollution, 

airspace congestion, and risk to crews and others. As a leader in the aerial survey industry, Keystone 

recognizes and supports the need to establish standards for UAS operators which will safeguard the 

NAS. That same experience, capability and commitment will enable Keystone to offer and conduct UAS 

operations using skilled professionals who will adhere to the required safety standards. 

The UAS operated by Keystone will be under 55 pounds including payload, will operate in a defined area 

made known to local ATC, and will not carry personnel, explosive materials or flammable liquid fuels or 

other potentially hazardous materials.