Geo - Rhea, LLC

3452 Rabel Mnt Rd South Charleston WV

25309 Debra Rohrer gimstl@msn.com 304 610 7107
June 11 , 2015 U.S. Department of Transportation Docket Operations 1200 New Jersey Ave., SE Wa shington, DC 20590 Re: Submission of Requests for Determination under Section 333 of the FAA Modernization and Reform Act and Exemption s Under 14 C.F.R. Section 11.81
Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”), Geo Rhea, LLC, (Geo - Rhea) hereby requests a determination by the Secretary of Transportation authorizing Geo - Rhea, LLC, to conduct commercial operation of its sUAS for the purposes of aerial inspection , volumetric analysis, geo spatial mapping, and 3D modeling of specific cell towers , power poles, land based materials, compressor stations , and Right of Wa ys (ROW) immedia tely adjacent to , for the telecommunication, electric utility, aggregate/coal, and oil and gas industries. Geo - Rhea’s a pplication of sUAS technology is based in Geographic Information System (GIS) data acquisition. Our mission is provide the above sited in dustries with accurate, geo - spatially located data , facilitating better decision making , safer operations, and minimizing hazardous situations when performing asset assessments. Operations will be conducted within and under the safeguards outlined herein and as may be established by the FAA under FMRA Section 333(c). Geo - Rhea also petitions for exemptions to effect the determination requested , pursuant to FMRA Section 333. The attached documentation includes detailed exemption requests that demonstrat e how these exemptions are in the public interest and will maintain at least an equal level of safety to exist ing regulations. Authorizing Geo - Rhea to conduct inspectio ns and geo spatial mapping of the sited assets and adjacent Right of W ays will pro vide increased asset awareness while minimizing risks involved with manual based data acquisition. The industries sited are mandated by regulatory agencies to perform asset and ROW inspections to minimize operational hazards , operate in the best interest of pu blic safety , and ensure delivery of criticalservices

. The industries sited are considered part of our national infrastructure and their safe

operational reliability is critical to the public’s well - being. Geo - Rhea’s sUAS services would enab le inspection s and operational e valuations to be conducted with less risk to personnel , increased accuracy, and more timely than current manually based inspections an d evaluations

. By providing geo - spatially referenced data that can be modeled, industry can locate ass ets precisely, respond according to need, and respond more appropriately to the need. A We st Virginia based example was the derecho of 2012 that impacted multiple states and caused millions of power outages. Crews and equipment were deployed without knowing exactly where or what damage had been done along isolated routes of the power lines. Additionally, reaching the sites to perform needed repairs , was complicated due to storm damage. sUAS technology, such as the VTOL Scout, could have assisted in mapping and assessing asset damage to ensure the right personnel and equipment was being deployed, thereby expediting restoration of services. The use of sUAS technology for the above stated purposes would:

 Reduce the risks associated with manual data capture  Increase asset integrity awareness based up on detailed geo - spatial data capture  Assist in determining preventable service interruptions  Assist in determining resources and actions required to operate and maintain assets  Assist in determining the fre quency and response to asset evaluation s  E xpedite data capture and transfer , allowing for more timely assessments  Allow for more frequent monitoring of facilities identified as at risk. Monitoring becomes a less resource availability driven task  Ensure access to facilities and assets for maintenance and hazard response through monitoring of adjacent ROWconditions  Facilitate actions to be taken to meet production requirements  Enhance emergency response based upon accurate geo - spatial mapping  Reduced env ironmental impact

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## Table of Contents

Geo - Rhea, LLC Corporate Profile / Capabilities 4 Aeryon Aircraft Description 6 Emergency Procedures and System Failures 9 EXHIBIT A - Exemption / Wa iver Requests 11 EXHIBIT B - Proposed Limitations and Conditions 18 EXHIB IT C - Summary of Geo - Rhea LLC Section 333 Exemption Request 19

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## Purpose Geo - Rhea, LLC (Geo - Rhea ) is applying for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow for commercial operation of its sUAS to conduct aerial inspection, volumetric analysis, geo spatial mapping, and 3D modeling of specific cell towers, power poles, land based materials, and compressor stations and Right of Wa ys (ROW)immediately adjacent to, for the telecommunication, electric utility, aggregate/coal, and oil and gas industries. The proposed sUAS operations will decrease safety hazards , e nhance decision making through providing timely, accurate data , and enhance risk assessments and monitoring, thereby improving overall safety and operations. 

## Geo **- Rhea, LLC**  **Corporate Profile / Capabilities** Geo - Rhea was founded in 2010 to provide geo - spat ial mapping capabilities using sUAS technology to perform data acquisition for geo - spatial analysis. As it is critical to our intent to have geo - referenced data acquisition we elected to purchase the Aeryon Scout, a craft that imbeds geo - tags in each photograph, has been vetted by the Canadian military, has redundant safety features, and is noted for its reliability in performance. Additionally Geo - Rhea will be purchasing the Aeryon SkyRanger, to allow for enhanced zoom capability for those clients requir ing more detailed information in more demanding situations. An example for a SkyRanger application would be cell tower inspections where the actual lettering on compo nents will need to be readable while maintaining a safe distance from the tower itself. Prior to notification by the FAA that sUAS commercial applications were not being allowed, Geo Rhea operated in Class G airspace, performing volumetric analysis coal companies based in We st Virginia. Geo - Rhea successfully modeled over 1,000 coal piles, red ucing what was a two week manual endeavor to a 2 1⁄2 day effort, with only 2 hours actual air time , each flight lasting approximately 15 minutes in duration. Our accuracy levels were determ ined to be in the +/- range of less than 5 % when calculated against calibrated scale weights. Manual crews averaged +/- 15% as they were unable to factor in slope erosion. Our performance not only assisted operations in determining how much more product was required, but we successfully provided the information within 24 hours of flight, giving the industry a more evergreen status of its current operations. Geo - Rhea lead the application of sUAS technology as a data acquisition tool for the purpose of mapping. As such we directly influenced the d evelopment of the technology, spec ifically in safety enhancements and flight maneuvering. Our objective has, and is, to safely capture maximum data in minimal time. W orking directly with tech support we were able to provide feedback that was incorpora ted into the Scout’s user interface, software, and performance.

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Geo - Rhea operated with a minimum of two persons on site at all times, a designated Pilot in Command (PIC), and at least on e spotter. The craft always remained within line of sight . Geo Rhe a has set forth Standard Operating Procedures (SOP) for the operation of its sUAS , including testing and validation of all equipment upon each launch and landing. These SOPs are provided to oversight industry state agencies for their approval and acceptan ce. Geo - Rhea employs two way communication devices at all sites for all persons. Personal Protection Equipment is provided for each person on site to allow for ready identification of all participants. Additionally, Geo Rhea participates in all safety t raining classes required at a given site as required by the client, as well as additional education classes as requested by the respective industries. Geo - Rhea’s PIC trained in the United States Air Force as a Crew Chief for the Pavelow- 53 helicopter, serving in Special Operations. He performed 6 tours of duty in the Middle East and Africa. His responsibilities covered all maintenance for the 50m PaveLow aircraft including , but not limited to , Marshall and Recovery, fueling and defueling, oversight of maintenance and crews, and all preflight and post flight inspections. Prior to being notified by the FAA in Sept. 2011, that commercial utilization of sUAS was not allowed, Geo - Rhea employed four persons, with combined service in the oil and gas industry of over thirty years. Geo - Rhea is aware requirements may be waived or adjusted according to application of the technology and experience of the operators. We respectfully request that our PIC’s military experience and training be a consideration wh en determining what requirements may be set forth. Geo - Rhea is further prepared to employ the services of a licensed pilot when and if deemed required for the type of work and areas in which we intend to operate.



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## Ae **ry on**  **Ae ry** **on Labs Corporate Description** Aeryon Labs is a Canadian developer and manufacturer of unmanned aerial vehicles. Founded in 2007, it is based in Waterloo, Ontario. The company is the world leader in sUAS VTOL systems having gained significant experi ence with its systems in military, commercial, and academic institutions around the world. Aeryon customers have accrued thousands of hours of flight experience and participated in the continuous improvement of the aircraft and its systems and payloads. The wide customer base includes military organizations in many countries, including Special Operations Forces in the US and Canada; and leading Universities in the US and Canada, including the University of Alaska, Northwestern Michigan College, and Kansa s State University. Numerous law enforcement agencies in the US and Canada have accumulated significant experience with Aeryon aircraft, as have major global petrochemical, oil and gas, and power companies. Together with its customers, Aeryon has gained a pprovals to fly in multiple countries around the world, including Canada and the UK, as well as Middle and Far Eastern countries. Aeryon aircraft have been approved for research purposes in multiple COAs through the US, contributing to significant develop ments and refinements in the aircraft.


### Ae **ry on A** **ircraft Description** The Aeryon Scout and Sky Ranger are quad - copter vertical takeoff and landing small UAS devices , with four rotors mounted on booms and four legs. Payloads are mounted underneath the fuselage on a gimbal mount. Communications use common frequencies and are digitally encrypted

. The aircraft are controlled with a tablet based intuitive user interface, allowing the PIC to fully focus on flight operations and mission execution . The aircraft are piloted by the use of a stylus, pointing to an area on a moving map display. Altitude is controlled by using a slider bar on the touch screen interface to command the aircraft to climb or descend. The system is fully stabilized and GPS g uided. Custom or commercially available map data in several formats may be used for operator orientation. The aircraft can be flown real -time by the operator or pre - programmed to fly a series of GPS waypoints. Wh ile the aircraft is flying its pre progra med flight path, the operator always has full control of the vehicle and can change its flight path or altitude immediately. Flight information such as position, altitude, environmental conditions, signal link strength, GPS signal strength, battery voltag e, and other flight data is displayed to the operator in real time. The aircraft constantly monitors environmental and system conditions and will alert the PIC to any abnormalities. The aircraft have built in failsafe mechanisms that allow return to the p oint of origin and vertical landing if emergency condition s exists.

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As both the aircrafts and payloads are gyro stabilized distance , from area of interest (AOI) may be maintained safely. This capability is of critical importance when flying vertical a ssets such as cell towers or performing high wall mapping for mining operations, allowing for pristine data capture while safe distances from the AOI is maintained.
Both crafts have a quick- change payload interface, including USB and Ethernet. The system s detect the payload connected, configure and operate accordingly . The payload capacity of the system is 250 g (0.55 pounds). Available payloads include gimbal - mounted digital still and video cameras, a near IR camera for remote sensing, a FLIR nigh t-vision camera, and a stabilized 30x Optical Zoom. 

### Ae **ry on Scout Technical Specifications**  Deployment Vertical Take - off and Landing Operation Range 1 Mile Operational Duration Up to 20 Minutes Operational Velocity Up to 30 mph Wi nd Limits Up to 30 mph (Gusts up to 50 mph) Dimensions 31.5 in. x 31.5 in x 7.9 in Max W eight 3.4 pounds Power Source 11.1V Intelligent LiPo Battery **Ae ry** **on Sky**

**Ranger Technical Specifications** Deployment Vertical Take - off and Landing Operation Range 2 Miles Operational Duration Up to 50 Minutes Operational Velocity Up to 30 mph Wi nd Limits Up to 40 mph (Gusts up to 55 mph) Dimensions 40 in. x 40 in. x 9.3 in. Max W eight 5.3 pounds Power Source 14.8V Intelligent LiPo Battery

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**Command and Control Sy stems**  Telemetry data is transmitted to the command station at least once per second. The display screen provides all essential data to the PIC, providing ability to control navigation and perform data entry. The Ground Control Station gives the PIC co ntinuous control over both aircraft and payloads

. Displayed on GCS:



### • Position



### • Navigation Route



### • Altitude



### • Heading



### • Battery voltage and time remaining



### • GPS signal strength



### • Radio link strength



### • Aircraft status to include error messages or failures



### • Date/time



### • Sensor position and orientation relative to sUAS **On -**  **board Flight Instruments** 

– The sUAS is equipped with an Inertial Navigation System (3 - axis gyroscope, magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for precision AGL altitude measurement. **On –**  **board computer systems**

– The sUAS is equipped with on - board computer systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry, etc.). **On -**  **board guidance and navigation equipment**

– The sUAS can operate autonomously; it does not req uire any input from ground - based equipment, or from the pilot to hover in place. **Frequency**

**A llocations** 

– 900 MHz and 2.4 GHz. **Fly aw**  **ay protection**

– To prevent a “fly away” or other potentially dangerous situations, the aircraft employs a system of fail - safes that will either return the aircraft to its home origin point or land the aircraft in its present position. See “Emergency Procedures and System Failures” in section 3 for additional detail. **Takeoff and Landing**

– The sUAS has vertical lift a utonomous launch and recovery. A Landing Zone (“LZ”) is designated by the operators and identified in the GCS software. For launch procedures the aircraft will take off and hover 3 meters directly above the LZ and hold until further operator instruction i s given. The aircraft will automatically adjust for wind during this period.

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**Navigation Sy stem** 
– Specific maps, such as air sectional and geographic maps, can be downloaded to the display screen and overlaid with GPS positional data. W aypoints 

### can be created before and during flight operation creating specific locations and sequences for the aircraft. **Redundant Sy stems** 
– The sUAS combines the input from a multitude of sensors. Even though the data from all sensors is required for optimal system p erformance, a single sensor malfunction is likely to result in degraded performance rather than leading to a catastrophic failure. 

## Emergency**Procedures and S ystem Failures**  **Engineered Failsafe Mechanisms Lost Communications**  Communication outages are detected by the system and are reported to the pilot. The system is designed to handle lost communications by instructing the craft to hover in place, climb to a pre set safe altitude, and then fly to its takeoff location. If comm unication is still not established the aircraft will descend slowly and make a landing at the point of takeoff. If interference or another overpowering signal is detected, the system will activate the lost communication procedure, climb to a safe altitude , fly home and land. In the missions Geo - Rhea performed before notification, this functionality was never activated by the aircraft. Wh ile brief lost communications were experienced never have they been sustained for such a duration as to make this fail safe mechanism activate. Our experience allows us to state that the reliability of the craft in maintaining communications is exemplary. 

### Communications Data Security All communication and video feed links are encrypted. The system and communication links are encrypted by the manufacturer’ s proprietary software. 

### Battery **Life** B attery voltage and flight time are displayed to the ope rator throughout the flight . The system continuously accounts for current environmental conditions, informing the PIC of estimated battery life remaining. At 3 minutes estimated flight time remaining, a warning is given to the operator. If the operator were not to bring the craft home, the system will assume safe transit altitude and return to known point take off. The sUAS is also equipped with an intelligent battery monitoring system that will allow it to leave its present position and fly home with reserve battery power to make a safe landing under current environmental conditions.

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**Ignition Source Resistant** Aircraft are equipped with a sealed LiPo battery pack and are operated by 4 brushless electric motors. The brushless motors, by design, do not spark or arc while being operated. The operating temperature of the motors and the battery is extremely low. 

### Potential Component Failures Automatic pre -flight checks prevent the UAS from taking off if detection systems determine unsafe conditions are present in the craft itself

. Additionally Geo - Rhea’s SOP require all compon ents be visually inspected prior to each flight. The crafts have highly sophisticated monitoring software incorporated into their design. Battery health, longevity, and temperature, voltage, GPS accuracy, vibration sensing, and yaw detection are examples of the inherent monitoring systems incorporated into the crafts. Wa rning notifications are provided to the PIC prior to any major failure allowing for pro - active preventative measures to be executed. A non -fatal e rror will prompt the system to return to its known point of take - off. A fata l error notification would prompt the system to land at its present location. PIC has the capability to move the craft to a more suitable and safer location to land. 

### Operational Boundaries Both the Scout and Skyranger allow for geo -fencing, defining , programmatically , boundaries where the craft is allowed to operate. Because Geo - Rhea operations are closely aligned with Geographic Information Systems based initiatives , our SOPs require we perform a thorough assessment of any areas where we expect to operate to identify any potential no fly area, based on airports, population, scheduled events, or other factors that may be of consideration. 

### Visual Line **- of** **- Sight Loss**  All sUAS flights will be conducted maintaining line - of- sight and be performed duri ng daylight, dawn to dusk, hours. If line - of- sight were to become obstru cted, the PIC will direct the aircraft to hover in place until line - of- sight is established.

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## EXHIBIT A **- Exemption / Waiv** **er Requests** The regulations from which Geo - Rhea seeks exemption a re as follows: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 47.3(b)(2); 14 C.F.R. 47.31(c); 14 C.F.R. 61.133(a)(1)(ii); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a) & (b). 1 

## EXEMPTION REQUEST **AN D EQUIVA**  **LENT LEVEL OF SA**  **FETY SHOWINGS UNDER**  **AP PLICA**  **BLE RULES SUBJECT TO EXEMPTION** Geo - Rhea, LLC, requests an exemption from the following regulations, as well as from any additional regulations that may be necessary to effect the Secretary’s determination under FMRA Section 333. 

### 14 C.F.R. Part 21, Subpart H: A**irw orthiness Certificate**  **s 14 C.F.R. §91.203 (a) (1)** Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the ai rcraft to be utilized by the Geo - Rhea , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and FMRA Section 333. The Federal Aviation Act (49 

### U.S.C.§ 44701 (f)) and FMRA Section

1 Exemptions from the requirements of sections 91.9(b), 91.203(a) and (b), 47.3(b)(2), and 47.31(c) of Title 14 C.F.R. are sought only in an abundance of caution, as they appear to be unnecessary given a recent FAA Interpretation. Memorandum from Mark Bury, FAA Assistant Chief Counsel for International Law, Legislation and Regulations, to John Duncan, Director, FAA Flight Standards Service (Aug. 8, 2014), available at http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/ 2014/duncan

- afs

- 1
- 2%20
- %20(2014)%20legal%20interpretation.pdf
.

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333 authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of thes e criteria demonstrates that the sUAS 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 aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the proposed restrictions and conditions. The sUAS to be operated is less than 7 pounds, fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates e xclusively within a defined secured area. Operations under this exemption will be tightly controlled and monitored by the operator under Geo - Rhea’s SOPs and in compliance with local public and facility safety requirements. Geo - Rhea will coordinate with th e FAA as necessary to obtain airspace waivers and to support the issuance of NOTAMs. Receipt of the prior permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safety. This provides at least an equivalent level of safety to that of operations conducted with conventional aircraft that would be orders - of- magnitude larger and would be carrying passengers, cargo, and flammable fuel. 

### 14 C.F.R. § 45.23 (b): Marking of the A**ircraft.** The regulation provides: Wh en 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 ne ar each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light- sport," "experimental," or "provisional," as applicable. Even though the s UAS will have n o airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” (or other marking as required by the FAA) can be placed. Given the size of the sUAV, two - inc h lettering will be impossible. The word “Experimental” (if required) will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety wil l be provided by having the sUAS marked on its fuselage as required by §45.29 (f) in such a manner that the pilot, observer and others working with the sUAS will see the identification. The FAA has issued the following exemptions to this regulation as Exemptions Nos. 10700, 8738, 10167 and 10167A.

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**14 C.F.R. §§ 47.3(b)(2) and 47.31(c): Carriage of Registration.**  These regulations require that an applicant for aircraft registration carry “in the aircraft” the second copy of the registration application as temporary authority to operate without registration. Given the size and configuration of this sUAS, there is no room to carry the document aboard the aircraft. Maintaining this document at the pilot’s control station would meet the intent of the rule and establish an equivalent of safety. 

### 14 C.F.R. § 61.133 (a) Commercial Pilot Privileges and Limitations. The regulation provides: A person who holds a commercial pilot certificate may act as pilot in command of an aircraft for compensation or hire, provided the person is qualified in accordance with this part and with the applicable parts of this chapter that apply to the operation. Because the FAA has not formally assigned a category or class to UAS, Geo - Rhea request an exemption to all category and class requirements of the commercial pilot certificate within the scope of this exemption Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. Geo - Rhea respectfully proposes that operator requirements should take into account the characteristics of the particu lar sUAS. Aeryon’s Scout and SkyRanger have a high degree of pre-programmed control and various built-in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption application. Th e risks associated with the operation of the Aeryon Scout and SkyRanger (accounting for size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial ope rations contemplated by Part 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the sUAS as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a).

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**14 C.F.R. §91.7(a): Civil Ai**  **rcraft Ai**  **rw orthiness.**  The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As th ere will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. All maintenance conducted on the aircraft will be accomplished according to the manufa cturer’s maintenance and operating procedures. Operators will strictly adhere to operating checklists and procedures for the aircraft in accordance with Geo - Rhea’s established SOPs which require thorough investigation of proposed site as it related to pub lic safety, proximity to airfields, pre and post flight inspections, safety training as required at site, personal protective equipment, and bi - directional communications . All PIC will be have proper training for safe operations of the aircraft (s) . Given the weight, speed, operational capability, and controlled flight environment of the sUAS, it will remain in a condition of airworthiness at an equivalent level of safety. 

### 14 C.F.R. § 91.9(b)(2): Civil **Ai rcraft Flight Manual in the A** **ircraft.** The regulation provides: No person may operate a U.S. - registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any comb ination thereof. Given the size and configuration of the sUAS, there is no room or capacity to carry a flight manual on the aircraft. The equivalent level of safety will be achieved by keeping the flight manual at the ground control station where the PIC flying the sUAS will have immediate access to it. The FAA has issued to Tri mble and others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, a nd 10700. 

### 14 C.F.R. §91.119: Minimum Safe A**ltitudes.** Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for sUAS that are multi - rotor VTOL that can be considered helicopters and the exemption requests authority to operate at altitudes up to 400 A GL, or not more than 100 above an object to be inspected, an exemption may be needed to allow such operations. As set forth herein, the sUAS will n ot operate at higher than 400 AGL.

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The equivalent level of safety will be achieved given the size, weigh t, and speed of the sUAS, as we ll as the location where it is operated. As Geo - Rhea will be performing work on lands typically owned by the requesting client, and frequently located in remote areas, notifications to the general public will rarely be requi red. At such time as the general public would need notification Geo - Rhea will work with the client to ensure proper notifications are made. Understanding that flight operations for like purposes with manned aircraft or rotorcraft we ighting far more tha n the maximum 7 pounds proposed herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition, the low- altitude operations of the sUAS will ensure separation between these sUAS operations and the operations of conventional aircraft that must comply with Section 91.119. 

### 14 CFR § 91.119: Minimum Safe A**ltitudes** Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsely populated areas . In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. Geo - Rhea will never operate at higher than 400 feet AGL. It will, however , operate to avoid congested or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey, mapping and inspection work must be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Sectio n 91.119(c) is needed. The equivalent level of safety will be achieved given the size, weight, speed, and material with wh ich the respective VTOLs are built. Also, no flight will be taken without the permission of the land owner or those who control th e land. Because of the advance notice to the landowner, all affected individuals will be aware of the flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 7 lbs. and carrying flammable fuel, any risk as sociated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. T he low-altitude operations of the sUAS technology will facilitate maintain ing separate air space between sUAS opera tions and conventional aircraft that must comply with Section 91.119.

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**14 C.F.R. §91.121: A ltimeter Settings.**  This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “... to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead GPS altitude control, an exemption may be needed. An equivalent level of safety will b e achieved by the operator as the sUAS uses AGL height from its initialization (launch) point, cross - referenced with MSL altitude of the launch point. 

### 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions. Section 91.151 (a) prohibits an individual from beginning “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) Dur ing the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The battery powering the sUAS provides approximately 20 minutes , Scout, and 4 5 minutes SkyRanger, of powered flight, which is less than the required re serve for a VFR day flight. Geo Rhea believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a) ). Operating the sUAS, in a tightly controlled area where only people and property owners or official representatives who are made aware of the operation will be allowed, 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 of the small UAS. Additionally, without exemption from 91.151(a), the sUAS would not be able to launch for any flight. Geo - Rhea believes that an equivalent level of safety can be ach ieved by first implementing operational limitations on flight times. The battery capacity will be monitored in flight and the flight will be terminated when 25% of the battery capacity is remaining. This restriction will be more than adequate to return t he aircraft to its planned landing zone from anywhere in its limited operating area. The second level of safety is achieved through the use of an aircraft battery monitoring system. The aircraft system will alert the operator of low battery voltage and re turn the aircraft to its take off location before battery capacity is depleted. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

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**14 C.F.R. §91.203 (a) and (b): Carry ing Civil A**  **ircraft Certification and Registration.** 

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 certifica te. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The sUAS fully loaded weighs no more than 7 pounds and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. 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. 

### 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require that an aircraft operator or owner “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 p rescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Because these regulations and Part 43 apply only to aircraft with an airworthiness certificate, they will not apply to the sUAS. Ma intenance will be accomplished by properly certified and trained operators according to manufacturer’s published maintenance procedures, following the developed checklist and operating procedures for the aircraft. An equivalent level of safety will be ach ieved because these sUAS are very limited in size, carry a small payload, and operate only in restricted areas for limited periods of time at an altitude not to exceed 400 feet AGL. If mechanical issues arise, the sUAS can land immediately and safely. As provided in the checklist, the PIC will ensure that the s UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. The PIC 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. Moreover, neither sUAS will allow flight if anomalies are detected.

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**EXHIBIT B -**  **Proposed Limitations and Conditions** These limitations and conditions to which Geo - Rhea agrees to be bound when conducting commercial operations under an FAA issued exemption include: 

### 1. The sUAS will weigh less than 7 pounds. 

### 2. The sUAS will go through a Failure Mode and Element Analysis (FMEA) to ensure the highest level of safety. 

### 3. The PIC will use a detailed checklist for every flight. 

### 4. Flights will be operated within line of sight of the pilot during daylight hours. 

### 5. Flights will be terminated no later than manufacturer designed return - home battery voltage or 25% remaining battery capacity. 

### 6. Flights will be operated at an altitude 400 feet AGL or lower. 

### 7. Minimum crew for each operation will consist of the sUAS Pilot and the Vi sual Observer. 

### 8. The sUAS pilot (operator) will be Pilot in Command (PIC). 

### 9. The sUAS will only operate within the lateral boundaries of customer property. Confined “Safe Zones” will be established for each flight. These zones will be free of unnecessary ha zards or risks and non - participating personnel. The Scout and Sky Ranger will operate with geo -fencing that will confine the aircraft to a pre - defined “operational box.” 

### 10. A briefing will be conducted with the customer prior to each sUAS operation. W ork w ill proceed only if customer and PIC determines sUAS operation is safe in the vicinity. This also gives permission to operate over the private, controlled - access property. 

### 11. Geo - Rhea will coordinate with the appropriate ATC facility or Flight Standards Di strict Office in order to obtain airspace waivers and effect issuance of NOTAMs, as necessary. 

### 12. Pilots will have been appropriately trained by the sUAS manufacturer or other authorized instructor, and current on its operation prior to flight. Observers w ill have been trained in operation of sUAS generally. 

### 13. The pilot and observer will have current specific safety training for the area in which sUAS operations will take place. 

### 14. The pilot and observer will at all times be able to communicate by voice. 

### 15. If t he sUAS loses command/control communications (C2) or loses its GPS solution, the UAS will have capability to return to a pre - determined location within the Safe Zone and land. 

### 16. The sUAS will have the capability to abort a flight in case of unpredicted obs tacles, emergencies, or system anomalies.

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**EXHIBIT C -**  **Summary of Geo**  **- Rhea**  **LLC . Section 333 Exemption Request**  Docket Number: FAA- 2014 -XXXX Petitioner: Geo - Rhea, LLC Sections of 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 47.3(b)(2); 14 C.F.R. 47.31(c); 14 C.F.R. 61.133(a)(1)(ii); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); a nd 14 C.F.R. 91.417(a) & (b). Description of relief sought: The petitioner seeks exemptions in order to commercially operate its small UAS to conduct aerial inspection, volumetric analysis, geo spatial mapping, and 3D modeling of specific cell towers, power poles, land based materials, and compressor stations and Right of Wa ys (ROW ) immediately adjacent to, for the telecommunication, electric utility, aggregate/coal, and oil and gas industries.