### June 25, 2015

Exemption No. 11907 Regulatory Docket No. FAA

–2015

–1238

Mr. Jerry Robinson Geum Services, Inc. P

.O

. Box 035 Richland, MI 49083

Dear Mr. Robinson:
This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated April 20, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf ofGeum Services, Inc. (hereinafter petitioner or operator) for an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to aerial photography and aerial video services

. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 and a DJI Phantom 3

. The petitioner requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U

.S

.C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the

### 2
aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA f inds that the requested relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary.
The Basis for Our Decision You have requested to use a UAS for aerial data collection1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos

. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

• They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

• A grant of exemption is in the public interest.

Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Geum Services, Inc. is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3
Conditions and Limitations

In this grant of exemption, Geum Services, Inc. is hereafter referred to as the operator. Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 and the DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

. 2. Operations for the purpose of closed

-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

-issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents,

### 4 the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine the UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraf t is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

### 5
14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the Administrator or any law enforcement official upon request.

17. 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.

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

-determined location within the private or controlled

-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

### 6
22. All aircraft operated in accordance with this exemption must 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 must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 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 in a manner ensuring the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects 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. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

### 7 If this exemption permits operations for the purpose ofclosed

-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;
c. Name and phone number of the person responsible for the on

-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used;
e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

### 8 This exemption terminates on July 31, 2017, unless sooner superseded or rescinded. Sincerely,

/s/ John S. Duncan Director, Flight Standards Service

EnclosuresApril 20, 2015

U.S. Department ofTransportation, Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Attn: Petition of Geum Services, Inc. for Exemption Pursuant to Section 333 ofthe FAA Reform Act
To Whom It May Concern:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 11, Geum Services, Inc. ("Petitioner"), assists in the management of large property holdings. These properties can be a mixture of natural or restored habitat areas adjacent to more managed areas that include pasture or commercial row crops, and areas of managed turf grass. Access to aerial images will provide large format over-view of property segments allowing for timely and efficient visual verification of properties and field boundaries, wildlife movements and management, invasive species verification, tracking, monitoring and management control outcome verification. Monitoring ofwetlands, woodlands, and open areas grasslands will be made effective, timely, and less invasive through the use of an aerial platform with high-resolution optical capabilities. Geum services also will provide aerial photography and aerial video services, for golf courses, real estate realtors and for additional photography and video needs such for personal events such weddings, etc. Geum Services hereby applies for an exemption from Federal Aviation Regulations ("FARs") identified below, to allow_commercial operation of small unmanned aerial vehicles (i.e., small unmanned aircraft systems or "s-UAS").
This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed Geum Services, Inc. Manual 1 ("Manual"), the s-UAS manufacturer's operations and/or instructions manual ("Aircraft Operations Manual"), and any other requirements established by the FAA pursuant to Section 333 ofthe Reform Act.

1 Petitioner submits this Manual as a Confidential document under 14 C.F.R. § 11.35(b), as the entire Manual contains confidential commercial and proprietary information that the Petitioner has not and will not share with others. The Manual contains operating conditions and procedures that are not available to the public and
are protected from release under the Freedom of information Act 5 U.S.C. § 552

For your convenience, this petition is organized as follows:

I. Petitioner's Description II. Relevant Statutory Authority Ill. Qualification for Approval Under Section 333 ofthe Reform Act IV. Description of Proposed Operations V. Regulations From Which Exemption is Requested
A. 14 C.F.R. Part 21, Subpart H2Airworthiness Certificates 

### & 14 C.F.R. § 91.203(a)(1).

B. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft.
Page 1

# J

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

D. 14 C.F.R. § 61.113 (a) 

### & (b): Private Pilot Privileges and Limitations: Pilot in Command.

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

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness.
G. 14 C.F.R. § 91.103: Preflight Action.

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

I. 14 C.F.R. § 91.119: Minimum Safe Altitudes.
J. 14 C.F.R. § 91.121 Altimeter Settings.

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

L. 14 C.F.R. § 91.203 (a) 

### & (b): Carrying Civil Aircraft Certification and Registration.

M. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b): Maintenance Inspections.
VI. Public Interest V

II. Privacy

VIII. Federal Register Summary

IX. Conclusion April 20, 2015

I. Petitioner's Description- Petitioner is affiliated with Geum Services, Inc. Geum Services, In building upon years of experience in video and photography the Petitioner would like to add to their services aerial video and photography. The Petitioner is well qualified to perform the proposed s-UAS operations. Having over 2 years' experience in flying s-UAS recreationally. II. Consistent with the requirements of 14 C.F.R. § 11.81(a), Petitioner provides the following information in support of its petition for exemption: Ill. The name and address ofthe Petitioner is: Geum Services, Inc. Attn: Steve Allen and Jerry Robinson and PO Box 035 Richland, Ml 49083. Phone: 1-269-760-0484 and 1-269-370-0150 Email: jrob@me.com 

### & SteveA@prairiesmoke.com IV. Relevant Statutory Authority This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. In the Reform Act, Congress directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system" and, under Section 333 ofthat law, directed the Secretary ofTransportation ("FAA Administrator") to consider whether certain unmanned aircraft systems may operate safely in the National Airspace System ("NAS") before completion ofthe rulemaking required under Section 332 ofthe Reform Act.3 V. In making this determination, the Secretary is required to determine which types of s-UASs do not create a hazard to users ofthe NAS or the public or pose a threat to national security in light ofthe following: Reform Act§ 333{a).

Page 2a. The s-UAS's size, weight, speed, and operational capability; b. Operation ofthe s-UAS in close proximity to airports and populated areas; and
c. Operation ofthe s-UAS within visual line of sight ofthe operator. d. Ifthe Secretary determines that such vehicles "may operate safely in the National Airspace System, the Secretary shall establish requirements for the safe operation of such aircraft in the National Airspace System" (Emphasis added)
e. In addition, the FAA Administrator has general authorityto grant exemptions from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from a requirement of regulations prescribed pursuant to section 44701(a)±(b) and sections 44702±44716).

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; FAA, Petition for Exemptions.

Ill. Qualification for Approval Under Section 333 ofthe Reform Act The proposed operations in this petition for exemption qualify for expedited approval under Section 333 ofthe Reform Act. Each ofthe statutory criteriaI and other potentially relevant factors are satisfied.
The proposed operations would permit the use of small and relatively inexpensive s-UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access, and; (4) would provide an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same purpose. Petitioner's s-UASs are rotorcraft, weighting 55 or fewer lbs. including payload. (5) They operate, under normal conditions, at a speed of no more than 27 knots and have the capability to hover, and move in the vertical and horizontal plane simultaneously. (6)Petitioner's s s-UASs will operate in line-of-sight and will operate only within a sterile area described in the enclosed Manual. (7)Such operations will insure that the s-UAS will"not create a hazard to users ofthe National Airspace System
or the public."

Given the small size ofthe s-UASs involved and the restricted sterile environment within which they will operate, this petition for exemption falls squarely within that zone of safety i.e., an equivalent level of safety, Page 3in which Congress envisioned that the FAA must, by exemption, allow commercial operations of s-UASs to
commence immediately. Also, due to the size ofthe s-UASs and the restricted areas in which the ss-UASs will operate, approval ofthe application presents no national security issue. Considering the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing s-UASs for the proposed operations, the grant ofthe requested exemptions is also in the public interest. Accordingly, Petitioner respectfully requests that the FAA grant the requested exemption without delay.
IV. Description of Proposed Operations
The enclosed Manual describes, in detail, the policies and procedures for Petitioner's proposed s-UAS operations. To assist the FAA in its safety assessment of Petitioner's proposed s-UAS operations, below is a summary of operational limitations and conditions which will ensure an equivalent or higher level of safety to operations conducted under current regulatory guidelines:

1. The ss-UAS will weigh less than 55 lbs.

2. Flights will be operated within line-of-sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 25 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 25 minute limit. 4

4. Flights will be operated at an altitude of no more than 400 feet above ground level ("AGL").

5. Minimum crew for each operation will consist ofthe s-UAS Pilot.
6. The s-UAS pilot will be a well qualified drone pilot with the appropriate practice and certification required by the FAA.

7. The s-UAS pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the s-UAS Pilot is present and possesses the necessary PIC qualifications, that person can also be designated as PIC.
8. The s-UAS will only operate within a confined "Sterile Area" as defined in the Manual.
9. A briefing will be conducted in regard to the planned s-UAS operations priorto each day's activities. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe safety perimeter be present for this briefing.
10. Pilot and Observer will have been trained in operation of s-UAS generally and will have received up-to-date information on the particular s-UAS to be operated, as required in the Manual.

11. Pilot will at all times be able to communicate by voice.

12. Written and/or oral permission from the relevant property holders will be obtained.
13. All required permissions and permits will be obtained from territorial, state, county or cityjurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

Page 414. Ifthe s-UAS loses communications or loses its GPS signal, the s-UAS is equipped with advanced safety features that will allow the s-UAS to automatically return to a predetermined location.

15. The s-UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

VI. Regulations From Which Exemption Is Requested
The Federal Aviation Act expressly grants the FAA the authorityto issue exemptions. By its terms, this statutory authority includes exempting civil aircraft, as the term is defined under §40101 ofthe Act, including s-UASs, from its safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest.
Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 and 91 for purposes of conducting aerial surveys and inspections using s-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 equal to or better than the rules from which exemption is sought. 10 A. 14 C.F.R. Part 21, Subpart H Airworthiness Certificates & 14 C.F.R. § 91.203(a)(1).
This petition seeks an exemption from 14 C.F.R. Part 21, Subpart 

### H, which establishes the procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a) (1). Given the size and limited operating area associated with the s-UAS to be utilized by the Petitioner, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe particular s-UAS.
In all cases, an analysis ofthese criteria demonstrates that the s-UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and conditions ofthe proposed s-UAS operations. Equivalent Level of Safety
The s-UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, the proposed operations in this petition for exemption will be controlled and monitored by the operator, pursuant to the Manual's requirements. Moreover, the FAA will have advance notice of all operations conducted under this exemption.

Page 5The s-UAS to be operated hereunder weighs less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured
area as set out in the Manual. Unlike other civil aircraft, the proposed operations in this petition for exemption will be controlled and monitored by the operator, pursuant to the Manual's requirements. These safety enhancements, which already apply to civil aircraft operated in connection with existing inspection operations, provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the s-UAS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.



### B. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft. 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification of normal category rotorcraft. To the extent the Petitioner's s-UASs would otherwise require certification under Part 27, as a rotorcraft, Petitioner airworthiness standards for the same reasons identified in the exemption request from 14 C.F.R. Part 21, Subpart H.
C. Aircraft Marking and Identification Requirements: 14 C.F.R. §§ 91.9(cL 45.23(b) and 45.27(a). This petition seeks an exemption from the aircraft marking and identification requirements of 14 C.F.R. §§ 91.9(cL 45.23(b) and 45.27(a). 14 C.F.R. § 91.9(cL 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 ofthis chapter. 14 C.F.R. § 45.23(bL Markings ofthe 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 13 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(aL Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces ofthe cabin, fuselage, boom, or tail the marks required by §45.23. Exemption from§ 45.23(b) is warranted because the s-UAV has no entrance to the cabin, cockpit, or pilot station on which the word "Experimental" can be placed. Moreover, given the size ofthe s-UAV, two-inch letteringwould be impossible.
The word "Experimental" will be placed on the fuselage in compliance with§ 45.29(f). Given the nature ofthe specific relief sought by this exemption request, Petitioner requires relief from the associated marking and identification requirements of§ 45.27(a) and § 91.9(cL which would require compliance with§ 45.23(b) Equivalent Level of Safety

An equivalent level of safety for exemptions to the aircraft marking and identification requirements of§§ 91.9(cL 45.23(b) and 45.27(aL will be provided by having the UAV marked on its fuselage as required by §45.29(f) where the pilot, observer, and others working with the UAV will see the identification ofthe s-UAS as "Experimental." Additionally, Petitioner will ensure compliance with any requests of s-UAS marking by the FAA. The FAA has issued the following exemptions to the aircraft marking requirements of§ 45.23(b): Exemptions Nos. 10700, 8738, 10167 and 10167A. 

### D. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. This petition seeks an exemption from the private pilot privileges and limitations of§ 61.113 (a) 

### & (bL which states: Private Pilot Privileges and Limitations: Pilot in Command. (a)
Page 6Except as provided in paragraphs (b) through (h) ofthis section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire;
nor may that person, for compensation or hire, act as pilot in command ofan aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. Section 61.113(a) limits private pilots to being in command of non-commercial flights. Section 61.113(b)(1) provides an exception that allows a private pilot to command an aircraft without passengers or property, in connection with business or employment if "[t]the flight is only incidental to that business or employment." That exception likely does not apply to the proposed operations under this petition for exemption, as the flights are not incidental to the proposed aerial surveys and inspections but rather essential to it. Accordingly, this petition seeks an exemption to§ 61.113(a)'s commercial limitation and/or§ 61.113(b)(1)'s requirement that the flight be incidental to the business to benefit from the exception. Equivalent Level of Safety As required by the Manual, Petitioner's s-UAS operators acting as PIC will hold a commercial and/or private pilot certification and have a rotorcraft rating. Because the s-UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety to§ 61.113 (a) and (b), by requiring the PIC operating the s-UAS to have either a commercial and/or private pilot certification with rotorcraft rating. Unlike a conventional aircraft that carries the pilot and passengers, the s-UAS is remotely controlled with no living thing on board. Moreover, the area of operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by
a single individual holding a commercial pilot's certificate operating a conventional aircraft in accordance with § 61.113 (a) 

### & (b). The risks associated with the operation of small, lightweight s-UAS are diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing the proposed operations in this petition for exemption with a private pilot as the PIC exceeds the present level of safety achieved by§ 61.113 (a) 

### & (b). E. 14 C.F.R. § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft. This petition seeks an exemption from the flight manual requirements of 14 C.F.R. § 91.9(b)(2), which states: (b) No person may operate a U.S.-registered civil aircraft2 (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis 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. Given its size, configuration, and load capacity, the s-UAS has no ability to carry such a manual on the aircraft, not only because there is no pilot on board, but because there is simply no room or capacity to carry such an item on the aircraft. Equivalent Level of Safety The safety related purpose ofthis manual requirement can be equally satisfied by maintaining the s-UAS flight manual at the ground control point where the pilot flying the s-UAS will have immediate access to it. Accordingly, Petitioner requests an exemption from§ 91.9(b )(2)'s flight manual requirements, on the condition that the s-UAS flight manual be available at the control point during each operation. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602,32827, and 10700. F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness. This petition seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in an airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued for the s-UAS, should this
Page 7exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Equivalent Level of Safety UtilityAerial Services pilots that will be flying the s-UAS have over 2 years and good safety record. Given the size ofthe s-UAS and the requirements contained in the Manual for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be provided. The FAA has issued the following exemptions to this regulation: Exemption Nos. 

### 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 

### 32827, and 10700. G. 14 C.F.R. § 91.103: Preflight Action.
This petition seeks an exemption from§ 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. Inasmuch as an FAA approved flight manual will not be provided for the s-UAS, an exemption will be needed. Equivalent Level of Safety An equivalent level of safety will be provided by following the Aircraft Operations Manual comprehensive preflight checklist. The PIC will take all actions, including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance data, before initiation of flight. H. 14 C.F.R. § 91.109(a): Flight Instruction. This petition seeks an exemption from 14 C.F.R. § 91.109(aL which provides that person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully s-UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Instead, flight control is accomplished through the use of a control box that communicates with the s-UAS via radio communications. Equivalent Level of Safety Given the size and speed of the s-UAS, an equivalent level of safe training can still be performed without dual controls because no pilot
or passengers are aboard the s-UAS, and all persons will be a safe distance away should the s-UAS experience any difficulties during flight instruction. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K 

### & 9862A. I. 14 C.F.R. § 91.119: Minimum Safe Altitudes. T
This petition seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. 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)(1) allows for a hazard to persons helicopter complies with any routes or altitudes specifically prescribed for helicopters. Equivalent Level of Safety Compared to flight operations with rotorcraft weighting far more than the maximum 55 lbs. proposed herein, and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft. An equivalent level of safety will be achieved given the 

### size, weight, speed ofthe s-UAS as well as the location where it is operated. As set forth in the Manual, the s-UAS will be operated in a restricted area, where buildings and people will not be exposed to operations without their pre-obtained consent.16 No flight will be taken without the permission ofthe property owner and/or local officials. Because ofthe advance notice to the property owner and participants, all affected individuals will be aware ofthe planned flight operations as set forth in the Manual. Furthermore, by operating at such lower altitudes, the s-UAS will not interfere with other aircraft that are subject to the minimum safe altitude regulations. 

### J. 14 C.F.R. § 91.121 Altimeter Settings. This petition 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 ofthe departure airport or barometric pressure. An exemption is required because the s-UAS does not have a barometric altimeter, but rather a GPS altitude

Page 8read out. Equivalent Level of Safety An equivalent level of safety will be achieved by following the procedures set forth in the Manual. As prescribed in the Manual, the operator will confirm the altitude ofthe launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to constantly monitorthe s-UASs height, thus ensuring operation at safe altitudes. K. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in V FR Conditions.
This petition seeks 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 afterthat for at least 45 minutes. The battery powering the s-UAS provides approximately 25 minutes of powered flight. An exemption from the 30 minute reserve requirement in 14 CFR §91.151 is therefore required.

An equivalent level of safety can be achieved by limiting flights to 25 minutes or 25% of battery power, whichever happens first. This restriction would be more than adequate to return the s-UAS to its planned landing zone from anywhere within its limited operating area. Operation ofthe s-UAS with less than 30 minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small s-UAS. Moreover, operation will be limited to controlled areas where only people and property owners, or official representatives who have signed waivers will be allowed.
This request for exemption falls within the scope of prior exemptions. See e.g. Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with§ 91.151 (a)); see also Exemptions 2689F, 5745, 10673, and 10808. L. 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration. This petition seeks an exemption from civil aircraft certification and registration requirements of 14 C.F.R. § 91.203 (a) and (b). The regulation provides in pertinent part: (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) ofthis 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. In addition to the fact that Petitioner is seeking an exemption from the airworthiness load capacity and size does not allow it to carry certification and registration documents; (2) The s-UAS does not have a cabin or cockpit entrance at which the documents could be displayed; and (3) There are no passengers or crew for whom the certificates need be displayed.
To the extent these regulations are applicable to the proposed s-UAS operations, an equivalent level ofsafety will be achieved by keeping these documents at the ground control point where the pilot flying the s-UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. M. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b): Maintenance Inspections.

Page 9This petition seeks an exemption from the maintenance inspection requirements of 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (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 as prescribed in subpart Eofthis part and shall between required inspections

... have

An exemption to these regulations is needed because Part 43 and these sections apply only to aircraft with an airworthiness certificate, which the s-UAS will not have.

An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the Aircraft Operations Manual as referenced in the Manual.19 As provided in the Manual, the operator will ensure that the s-UAS is in working order priorto initiating flight, perform required maintenance, and keep a log of any maintenance performed. The operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. If mechanical issues arise, the s-UAS can land immediately and will be operating from no higher than 400 feet AG L. Moreover, the s-UAS's small size, carrying capacity, and the fact that flight operations will onlytake place in restricted areas for limited periods oftime, create less risk than the same factors associated with conventional fixed-wing aircraft and rotorcraft performing the same operation.
Public Interest Consistent

With the requirements of 14 C.F.R. §11.81(d), Petitioner offers the following reasons why granting this petition for exemption is in the public interest, i.e., how granting it would benefit the public as a whole. Approval of exemptions allowing commercial operations of small and lightweight s-UAS in the utility aerial services industry benefits the public as a whole in the following ways:
It helps fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act, namely, the FAA Administrator's assessment ofwhether certain s-UAS may operate safely in the National Airspace System before completion ofthe rulemaking required under Section 332 ofthe Reform Act.
The operation significantly improves safety and reduces risk by alleviating human exposure to danger associated with current aerial survey and inspection methods, namely, full size helicopters. Manned helicopters performing utility-power generation inspections and patrols have experienced an exceedingly high number of accidents and fatalities.
Petitioner's s-UASs are battery powered and create no emissions. If Petitioner's s-UAS crashes, there is no fuel to ignite and explode. Any impact of Petitioner's lightweight s-UASs is, obviously, far less than a full size helicopter. The public's interest is furthered by minimizing ecological impact of an accident and by reducing human exposure to potentially harmful emissions associated with manned aircraft. x Aerial surveys are valuable tools for utility-power generation inspections. However, problems with safety, cost, statistical integrity, and logistics continue to impede aerial surveys and inspections from conventional manned aircraft. The use of s-UAS addresses these problems and is a powerful tool for performing a wide-range of applications. Privacy
All flights will occur over Petitioner's property or the Customer's property with the Customer's prior consent and knowledge.
Page 10VIII. 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: Utility Aerial Services, Inc. seeks an exemption from the following rules: 14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 C.F.R. § 61.113 (a) 

### & (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) 

### & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417 (a) 

### & (b). Approval of exemptions allowing commercial operations of small and lightweight unmanned aircraft ("s-UAS") in the utility-power inspection industry will enhance safety by reducing risk. Conventional operations in this industry using rotorcraft or fixed-wing aircraft present the risks associated with vehicles that weigh in the neighborhood of several thousand pounds and carrying large amounts offuel. Such aircraft must fly to and from the survey or inspection location and operate at low altitudes. In contrast, a s-UAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all ofthat risk, given the reduced mass and lack of combustible fuel carried on board. The s-UAS is transported, not flow, to the designated survey area and set up. The s-UAS carries no passengers or crew and, therefore, does not expose them to the risks associated with manned aircraft flights. The operation of small s-UASs, weighting less than 55 lbs., provides an equivalent level of safety and thus supports the grant ofthe exemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight s-UASs operate at slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional aerial survey of golf course and real estate than op
Conclusion
Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of 2012 size, weight, speed, operating capabilities, proximity to airports and populated areas, and operation within visual line of sight and national security2provides more than adequate justification for the grant ofthe requested exemptions allowing commercial operation of Geum Services, conducted with fixed-wing aircraft or helicopters.

Manuals and Specifications:

- DJI Phantom 2 Manual can be found here: http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Pius_User_Manual_v1.8_en.pdf
DJI Phantom 3 is expected to be released by May 1, 2015. Here the link to theirfly safe program. http:/ /flysafe.dji.com/

And the link to their specs page: http:/ /www.dji.com/product/phantom-3/spec The manual has not been released when it does, it will be posted online.
If additional information is required, or ifyou have any questions regarding this Petition for Exemption, please contact the undersigned Jerry Robinson, 269-760-0484 or Steve Allen, Geum Services President at: 269-370- 0150.

Jerry obinson jrob@me.com 269-760-0484 Page 11