GeoFlight Aerial Mapping Solutions, LLC

November 17, 2015

U.S. Department of Transportation  

Docket Management Facility

1200 New Jersey Ave. S.E.  

Washington, D.C. 20590

Please find enclosed a letter requesting an exemption under Section 333 of the Federal Aviation

Administration Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations

from certain provisions of Title 14 Code of Federal Regulations. This petition is written to be consistent

with the intent of The United States Congress to permit safe integration of small unmanned aircraft

systems (UAS) in the national airspace prior to the issuance of final regulations governing commercial

use of small UAS pursuant to Section 333 of the FAA Modernization and Reform Act of 2012.  This

request for an exemption is to safely operate a small UAS for use in aerial data collection. With safety of

the general public being the forefront of many of the FAA’s laws and regulations, it is the belief of

GeoFlight Aerial Mapping Solutions, LLC that safe integration to the national airspace can be achieved

with the combination of a highly skilled and safety orientated flight crew following procedures set forth

by the FAA. The benefit to the general public is just recently being unveiled through the endless uses of

small UAS’s to the commercial industry.  

Sincerely;

Jesrin Gaier

Business owner

Enclosure

 Jesrin Gaier
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GeoFlight Aerial Mapping, LLC

November 17, 2015

U.S. Department of Transportation  

Docket Management Facility

1200 New Jersey Ave. S.E.  

Washington, D.C. 20590

Re: Request for exemption under Section 333 of the Federal Aviation Administration (FAA)

Modernization and Reform Act of 2012 and Part 11 of the Federal Aviation Regulations from certain

provisions of Title 14 Code of Federal Regulations (C.F.R.).

Dear Sir or Madam,

GeoFlight Aerial Mapping, LLC (GeoFlight) respectfully submits this petition for exemption from

several provisions of Title 14 of the Code of Federal Regulations (C.F.R.), and more specifically portions

of Title 14 C.F.R. Parts 43, 45, 61 and 91. It is the belief of GeoFlight, that granting an exemption is

consistent with the intent of The United States Congress to permit safe integration of small unmanned

aircraft systems (UAS) in the national airspace prior to the issuance of final regulations governing

commercial use of small UAS pursuant to Section 333 of the FAA Modernization and Reform Act of 2012.  

This request for an exemption is to safely operate a small UAS for use in aerial data collection. This

includes, but is not limited to; aerial surveying and data acquisition of above ground mines, quarries,

landfills agriculture plots, forestry, inspections, golf courses, construction and real estate in rural areas

of the United States as long as such operations are performed within the conditions described below

and any conditions established by the FAA through the grant of this petition.

GeoFlight seeks an exemption from the following Federal Aviation Regulations:

14 C.F.R 21(h);  

14 C.F.R. 43.7;  

14 C.F.R. 43.11;  

14 C.F.R. 45.11;  

14 C.F.R. 45.23(b);

14 C.F.R. 45.27;  

14 C.F.R. 45.29;  

14 C.F.R. 61.101(e)(1) and (4) and (5);

14 C.F.R. 61.113(a) and (b);

14 C.F.R. 91.7(a);  

14 C.F.R. 91.9(b)(2) and (C);  

14 C.F.R. 91.103(b)(2);   

14 C.F.R. 91.105;   

14 C.F.R. 91.109;   

14 C.F.R. 91.119(c);        
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14 C.F.R. 91.121;   

14 C.F.R. 91.151(a);     

14 C.F.R. 91.203(a) and (b);   

14 C.F.R. 91.403;  

14 C.F.R. 91.405(a);     

14 C.F.R. 91.407(a)(1);       

14 C.F.R. 409(a)(1) and (a)(2); and       

14 C.F.R. 91.417(a) and (b)        

As the use of small UAS’s have become more popular and starting to be used in commercial

operations, Congress challenged the FAA to start to safely integrate commercial UAS use into the

national airspace based on seven factors outlined in Section 333 of the FAA Modernization and Reform

Act of 2012. These seven factors are; size, weight, speed, operational capability, proximity to airports,

proximity to populated areas, and operation within visual line of sight. In this petition, these seven

factors are supported through this exemption request.  

GeoFlight is seeking an exemption to use the senseFly eBee (eBee) and the DJI Phantom 3

Professional (Phantom), to carry sensors needed for data acquisition for projects across the United

States. The data collected will be used to limit the safety hazards of various activities associated to

traditional data collection of above described areas. The use of a small UAS will reduce the time spent by

surveyors and other professionals who may be subject to dangerous activities. These activities could

include unstable stockpiles or waste piles, walking near highwalls, working in close proximity to very

large heavy machinery and operating equipment. The use of UAS also mitigates the need for manned

aircraft which was traditionally the only means of gathering aerial data. The data collected with a UAS is

generally more accurate, safe, economical, efficient, and limits the environmental impact of manned

aircraft. UAS’s are able to fly at lower altitudes, this allows for better resolution in the data acquired

compared to manned aircraft. UAS’s also gives greater density to the data acquired compared to

traditional ground based surveying methods which has limited views of objects at any given time. The

data acquired through the use of the above systems will be used to assist mining companies, mine

operators, landfill operators, construction contractors, farmers, farm consultants, agronomists,

foresters, loggers, golf course operators, real estate agents, land owners, homeowners ect. to make

valuable decisions in a shorted period of time and with limited safety risks.  

The product produced from data acquired from a UAS can be used by the data analyst in a

matter of days. Currently, when I hire a manned aircraft to gather data for orthorectified aerial imagery

and elevation models, I do not receive the data for at least five to eight weeks after image acquisition

due to the post processing time needed. The data acquired with a small UAS uses a different technique

of post processing with overlapping images which is more efficient and accurate. This allows a more

time sensitive deliverable and quicker reaction times for the end user. Aerial imagery and the data that

can be extracted from the images can be an invaluable resource which has proven to be very beneficial

to professionals and landowners. All projects whether small or large, in primitive phases or final product

can greatly benefit from data gathered by a UAS. While aerial imagery can be such a valuable resource,

it is still financially out of reach for most companies and landowners when traditional manned aircrafts
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are used. With a manned aircraft, image resolution may be impracticable for the project due to the

altitude and speed a manned aircraft must maintain. When a manned aircraft is used instead of a UAS it

can put the general public at greater risk by operating in close proximity to the ground, trees,

infrastructure, and people. The additional risks involved with using a manned aircraft include; carrying a

manned crew, weighing thousands of pounds and carry highly flammable fuel.

The eBee and Phantom in this petition for exemption have both been approved for multiple

exemptions. Their level of safety has been demonstrated by responsible operators over the past couple

of years. Both of the UAS’s are small battery powered systems weighing 1.5 lbs. and 2.8 lbs. respectively,

inclusive of battery and payload. All aircraft in this petition 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. Both of the systems will be operated

using a radio frequency of 2.4Ghz. Any sensors used onboard the UAS will be in compliance with Federal

Communications Commission (FCC) requirements. All flights will not be flown at an airspeed exceeding

49knots. The UAS will not be operated within 5 nautical miles of an airport reference point as denoted

on a current FAA published aeronautical chart unless a Certificate of Waiver (COA) has been obtained

and a letter of agreement with that airport’s management has been received. If onboard sensors detect

an unsafe situation at any time during flight such as; low battery,  loss of GPS or radio signal, the system

will execute the pre‐programmed safety fail safes and automatically return to a predefined landing site.

With the small operational footprint and many safety fail safes, these systems provide an equivalent

level of safety compared to conventional operations conducted with helicopters and fixed‐wing

aircrafts. As a safe alternative, a UAS can be safely integrated into the national airspace for commercial

use as Congress intended, as long as they are operated under strict conditions proposed in this petition

and by following any conditions established by the FAA through the grant of this petition.

Each of the systems in this petition are fully capable to be flown by one person. To be in

compliance with this proposed exemption, a minimum of two crew members will have continuous

unaided sight of the system, airspace, and surrounding area during flight. The crew will consist of a pilot‐

in‐command (PIC) and at least one visual observer who will not be more that voice distance away from

the PIC. The PIC will have, at minimum, a sport pilot’s license and a third class medical certificate. The

PIC and visual observer will be trained in operation of the UAS. The PIC will have completed a minimum

of sixteen hours of flight time training with the UAS prior to commercial operations. The PIC will be

required to keep up with advancements of the UAS. GeoFlight has several rural flight testing areas

where each system can be flown. This allows the crew to test each system and learn how they react in

different conditions so they can be more than confident before conducting any commercial projects.  

The responsibility of the PIC will consist of five steps. First, the PIC will determine if the weather

conditions are favorable to maintain a safe flight according to manufactures specified limits of the

system based on battery life, weather conditions, flight duration ect. Second, a pre‐flight inspection with

an associated checklist will be thoroughly completed and any questionable sections of the pre‐flight

inspection will warrant a reschedule of the flight. All areas of the pre‐flight inspection will be

documented in a Maintenance and Inspection Manual. Third, the PIC will perform one last check of the

flight plan. Forth, during flight, the PIC will be responsible for a safe flight as the vitals of the system are
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monitored and unaided visual contact is maintained. Fifth, the PIC will perform a post flight inspection

with the associated checklist and document and notify the owner immediately with any repairs needed.

All areas of the post flight inspection will be documented in a Maintenance and Inspection Manual. A

summary of the standard operating procedure will include:

 Creating a new flight plan which takes in account the dangers of the surrounding area

 Simulating the flight plan with flight planning software and ground observance

 Prepare for a flight with site visual inspection, surrounding area visual inspection and pre‐flight

inspection documented in a Maintenance and Inspection Manual

 Perform flight after all safety considerations have been accounted for

 Post flight inspection documented in a Maintenance and Inspection Manual

 Perform observed maintenance from inspections and routine maintenance to the manufactures

recommendations.  

The responsibilities of the visual observer are very important to the safety of the flight and

consists of three steps. First, will be to assist in the pre‐flight inspection of the system with the PIC and

notify the PIC of any observed hazards in the airspace visual pre‐inspection. Second, during flight the

visual observer will be responsible for monitoring the surrounding airspace for other aircrafts, hazards

or unplanned situations, while keeping in voice contact with the PIC. Third, the visual observer will assist

the PIC during the post flight inspection.  

Most flights will also be autonomous, where a pre‐defined flight plan will be loaded into the

system before flight. This will define the exact flight plan to be flown with all safety concerns of the

airspace and surrounding area thoroughly analyzed an accounted for. The pre‐defined flight plan

generally consists of multiple waypoints in sequence at a specified altitude no greater than 400 feet

above ground level and guided by an onboard GPS and associated flight sensors. Manual override

control will always be available during autonomous flight in case of emergency or unexpected

conditions. The use of autonomous flight helps maintain the privacy of the surrounding properties. The

flight plan will be limited to the rural property which GeoFlight has been contracted to fly over. The

sensors used onboard will be focused on the contracted property which will limit concern to non‐

participating individuals. After the project is complete the data will be distributed only to those listed on

the signed contract or as directed by those in the contract.  

With safety of the general public being the forefront of many of the FAA’s laws and regulations,

it is the belief that GeoFlight operations will have an equivalent or greater level of safety than traditional

manned aircraft performing similar flights.  The combination of adhering to the guidelines set forth by

the FAA and a highly skilled and safety orientated flight crew following strict procedures of GeoFlight will

make this attainable. The benefit to the general public is just recently being unveiled through the

endless uses of small UAS’s to the commercial industry. The use of a UAS is making data more readily

available to those who could not afford a manned aircraft flight to obtain resources that will benefit

their project from start to finish. The vision of GeoFlight is to offer unmatched deliverables in the safest

and most affordable manner.  
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In the attachments of this application, are the specifications of the sensefly eBee and DJI

Phantom 3 Professional and a link to the full user manual. Both systems have been approved for

exemption in numerous applications due to the unparalleled level of safety that these UAS’s can achieve

with competent and skilled operators. Both systems are known for their safety records due to many

technical advancements geared around the safety of the general public. The systems have multiple pre‐

programmed fail safes in case of an emergency and flight controllers that can achieve a very stable flight

even in poor conditions. With the use of a safety oriented UAS, and a competent flight crew, combined

with strict safety procedures; the FAA can have confidence in the operations of GeoFlight.

The name and contact information of the applicant is:

Jesrin Gaier

Business owner

GeoFlight Aerial Mapping, LLC

13574 43rd Ave.  

Chippewa Falls WI, 54729

(952)388‐7870

gaierj@hotmail.com

Please contact me with any questions, concerns or if you require additional information or clarification.  

Thank you for your time.

Most Sincerely;

Jesrin Gaier

 Jesrin Gaier
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Attachments

Attachment 1

The full user manual for the senseFly eBee can be found at:

https://www.sensefly.com/fileadmin/user_upload/sensefly/documents/manuals/Extended_User_Manu

al_eBee_and_eBee_Ag_v16.pdf  

The specifications for the senseFly eBee are from pages 171 and 172 in the above link and are also in the

attachments of this application.    

Attachment 2

The full user manual for the DJI Phantom Professional can be found at:

http://www.dji.com/product/phantom‐3/download  

The specifications for the DJI Phantom Professional are from the appendix pages 54 and 55 in the above

link and are also in the attachments of this application.
Drone specifications

2 Drone specifications

Size Wingspan: 96 cm

Wing area: 0.25 m2

Weight without camera and battery approx. 0.42 kg (0.93 lbs)

Nominal take-off weight (approx.) eBee: 0.67 kg (1.48 lbs)

eBee Ag: 0.71 kg (1.56 lbs)

(with standard camera & battery)

Maximum take-off weight 0.75 kg (1.65 lbs)

Material EPP foam, carbon structure & composite parts

Battery 3-cell Lithium-Polymer (0.14 kg)

Nominal endurance (flight time)68 eBee: 50 minutes

eBee Ag: 45 minutes

(with standard camera)

Propulsion Electric brushless motor

Nominal static thrust: 0.63 kgf (6.2 N)

Nominal cruise speed 40-90 km/h (11-25 m/s or 25-56 mph)

Wind resistance up to 45 km/h (12 m/s)

Max. single flight coverage69 eBee: 12 km2(4.6 mi2)

eBee Ag: 10 km2(3.9 mi2)

(on a single battery charge)

68 can vary greatly depending on external factors such as wind, altitude change and temperature.

69 calculated based on the following test conditions: GSD of 30 cm (11.8 in) per pixel, no wind, moderate air temp. (18 C/64.4 F), new fully-charged battery, flight altitude of 1,000 m (3,280 ft) above

ground & take off at approx. sea level from centre of coverage area.

171

Attachment 1
Specifications

Communication devices Ground modem:

• Frequency: 2.4 GHz

• Range70: approx. 3 km

• Certification: FCC Part 15.247, IC RSS210, CE

Remote control:

• Frequency: 2.4 GHz

• Range: approx. 1 km

• Certification: CE, FCC

Navigation Up to 50 waypoints

GSD (per pixel) eBee: Down to 1.5 cm (0.6 in)

eBee Ag: Down to 2 cm (0.8 in)

Absolute horizontal eBee (with GCPs): Down to 3 cm (1.2 in)

accuracy eBee (no GCPs): 1 to 5 m (3.3 to 16.4 ft)

eBee Ag (with GCPs): Down to 4 cm (1.6 in)

eBee Ag (no GCPs): 1 to 5 m (3.3 to 16.4 ft)

Absolute vertical eBee (with GCPs): Down to 5 cm (2.0 in)

accuracy eBee (no GCPs): 2 to 5 m (6.6 to 16.4 ft)

eBee Ag (with GCPs): Down to 7 cm (2.8 in)

eBee Ag (no GCPs): 2 to 5 m (6.6 to 16.4 ft)

Relative orthomosaic/ 1-3 times GSD

3D model accuracy

Carry case dimensions 55 x 45 x 25 cm (21.6 x 17.7 x 9.8 in)

70 can vary greatly depending on external factors such as cruise altitude, presence of obstacles and

radio-frequency interference.

172
Attachment 2