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February 6, 201 5

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 Aeria l Surveys, Inc. (Keystone ) is petitioning the Federal Aviation Administration (FAA) for an exemption from the Federal Aviation Regulations ( FAR s ) requested below concerning small unmanned aerial systems (UAS). Section 333 of the FMRA promotes UAS integration into the national airspace by
grant ing the FAA authority to allow for the safe operation of certain UAS with in 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 Me asurement 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 pil ots, 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 nati onal security or privacy concerns2

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

As a data provider, K eystone will not be analyzing or interpreting data ; rather

, K eystone exists to provide Remote Sensing in a safe and effective manner for multiple industries and governmental uses. For this

reason, K eystone will use, in addition to other aircraft, the Altavian Nova F 65 00 (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 No s . 11111 and 11114 issued on December 10, 2014. The detailed specifications of the aircraft are listed in a section below

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

VO s 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

K eystone is requesting this exemption in order to provide s ervices 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/asses sment , etc. )

2. Government Agencies

– Federal, State and Local ( L ocal governments with limited budgets will
be better able to afford UAS surveys as opposed to manned flights)

3. Engineering

– M ining, waste disposal, pipelines, etc.
4. Insurance

– Claim assessment

5. Geographic Information Systems

– P opulating 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 fa ll 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 )

,
no t 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 ant icipation of meeting the known governmental need to cost effectively asses s 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 B ox 20159 Philadelphia, PA 19114 (215) 677

- 3119 dday@kasurveys.com

Exemption Requested: Key stone 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 req uirements

 14 CFR Section 91. 405 : Ma intenance requirements

 14 CFR Section 91.407: Maintenance requirements

 14 CFR Section 91.409: Inspection frequency

 14 CFR Section 91.417: Maintenance records

Keystone’s H istory

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 r ole as a part 91 operator . Keystone has long operated in compliance with the rules governing us e 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 consis ts 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 C onditions (VMC)

. 2. The UAS with pay load 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 with in 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 5 00 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 5 0 meters from all other paved roads.

9. The Pilot will have manufacturer training and flight hours with the Nova F6500 in accordance
with the K eystone FOM and the manufacturer’s requirements

. S pecifically, 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

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

12. In accordance to the K eystone 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 per formed 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 K eystone
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 maint enance 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 real

time 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 < 20l b s 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 undertak e as part of the UAS exemption. The
follow ing 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 fl y 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 cre w 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 measu res expected
of the pilot and industry do not require this license. Additionally, all pilots will be under the6

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 t hese 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 air worthy 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 are a made known to local ATC . Furthermore, the vehicles Keystone will operate do not carry personnel, explosive materials or flammable liquid fuels or oth er 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. Thi s UAS, piloted by Keystone’s pilots, do es 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 receive d 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 assu re that the UAS is operating safely with existing air traffic and poses
no risk to groun d assets and persons

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D. 14 CFR Section 91.121: Altimeter requirements

This section of Title 14 requires that the pilot of the aircraft us e an altimeter on board the a ircraft to determine altitude. The altimeter must be set based on the barometric pressure of the departing airport and airports i n route. Petitioner seeks an exemption from 14 CFR Part 91.121 as the aircraft
does not use an altimeter for elevation dete rmination , 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 p lan 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 sys tem 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 manufac turer’s
recommendation . This will ensure that the UAS lands safely at one of the two designated landing areas before battery life become s critical or unstable.

F. 14 CFR Section 91.405 , 14 CFR Section 91.407 , 14 CFR Section 91.409 , 14 CFR Section 91.417 :
M aintenance Reporting and Maintenance Inspection frequency

Petitioner seeks an exemption from the above regulations and th eir 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 airworthi ness certification, these regulations will not apply to these8

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 r epairs possible.

Equivalent Level of Safety

Using the manufacture r ’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 mai ntenance will be overseen by Keystone’s Director of Unmanned Airborne Vehicle
Maintenance ( DUAVM ) who will ensure that the inspections and preventativ e 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 DUAV M 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.

P ublic I nterest

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 th e 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 wi ll 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. T hat same experience, capability and commitment will enable Keystone to offer and conduct UAS operations using sk illed professionals who will adhere to t he 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.