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 

Washington, DC 20590

Re: Submission of Requests for Determination under Section 333 of the FAA Modernization 

and Reform Act and Exemptions 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”), GeoRhea, 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 Ways (ROW)

immediately adjacent to, for the telecommunication, electric utility, aggregate/coal, and oil and 

gas industries. Geo-Rhea’s application of sUAS technology is based in Geographic Information 

System (GIS) data acquisition. Our mission is provide the above sited industries 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 

demonstrate how these exemptions are in the public interest and will maintain at least an equal 

level of safety to existing regulations. Authorizing Geo-Rhea to conduct inspections and geospatial mapping of the sited assets and adjacent Right of Ways will provide 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 public safety, and ensure delivery of critical 
services. 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 enable inspections and operational evaluations to be 

conducted with less risk to personnel, increased accuracy, and more timely than current 

manually based inspections and evaluations. By providing geo-spatially referenced data that 

can be modeled, industry can locate assets precisely, respond according to need, and respond 

more appropriately to the need. A West 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 upon 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 frequency and response to asset evaluations

 Expedite 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 ROW conditions

 Facilitate actions to be taken to meet production requirements

 Enhance emergency response based upon accurate geo-spatial mapping

 Reduced environmental 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 / Waiver Requests 11

EXHIBIT B - Proposed Limitations and Conditions 18

EXHIBIT 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 Ways (ROW) immediately adjacent 

to, for the telecommunication, electric utility, aggregate/coal, and oil and gas industries.

The proposed sUAS operations will decrease safety hazards, enhance 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-spatial 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 

requiring more detailed information in more demanding situations. An example for a SkyRanger 

application would be cell tower inspections where the actual lettering on components 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, GeoRhea operated in Class G airspace, performing volumetric analysis coal companies based in 

West Virginia. Geo-Rhea successfully modeled over 1,000 coal piles, reducing 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 determined 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 development of the technology, specifically in 

safety enhancements and flight maneuvering. Our objective has, and is, to safely capture 

maximum data in minimal time. Working directly with tech support we were able to provide 

feedback that was incorporated into the Scout’s user interface, software, and performance. 
5

Geo- Rhea operated with a minimum of two persons on site at all times, a designated Pilot in 

Command (PIC), and at least one spotter. The craft always remained within line of sight. GeoRhea 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 acceptance. 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 training 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 when 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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Aeryon 

Aeryon 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 experience 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 Kansas 

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 approvals 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 developments and refinements in the aircraft. 

Aeryon Aircraft 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 guided. 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. While the aircraft is flying its preprogramed 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 voltage, 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 point of origin and vertical landing if emergency conditions

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 assets 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 systems

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 night-vision camera, and a stabilized 

30x Optical Zoom.

Aeryon 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 

Wind Limits Up to 30 mph (Gusts up to 50 mph) 

Dimensions 31.5 in. x 31.5 in x 7.9 in 

Max Weight 3.4 pounds 

Power Source 11.1V Intelligent LiPo Battery 

Aeryon 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 

Wind Limits Up to 40 mph (Gusts up to 55 mph) 

Dimensions 40 in. x 40 in. x 9.3 in. 

Max Weight 5.3 pounds 

Power Source 14.8V Intelligent LiPo Battery 
8

Command and Control Systems 

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 continuous 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 require any input from ground-based equipment, or from the pilot to hover in place. 

Frequency Allocations – 900 MHz and 2.4 GHz. 

Fly away 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 autonomous 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 is given. The aircraft will automatically adjust for wind during this 

period. 
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Navigation System – Specific maps, such as air sectional and geographic maps, can be 

downloaded to the display screen and overlaid with GPS positional data. Waypoints can be

created before and during flight operation creating specific locations and sequences for the 

aircraft. 

Redundant Systems – The sUAS combines the input from a multitude of sensors. Even 

though the data from all sensors is required for optimal system performance, a 

single sensor malfunction is likely to result in degraded performance rather than leading to a 

catastrophic failure. 

Emergency Procedures and System 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 preset safe altitude, and then fly to its takeoff location. If communication 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. While 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 

Battery voltage and flight time are displayed to the operator 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 

components 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. Warning 

notifications are provided to the PIC prior to any major failure allowing for pro-active 

preventative measures to be executed.

A non-fatal error will prompt the system to return to its known point of take-off. A fatal 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 during daylight, 

dawn to dusk, hours. If line-of- sight were to become obstructed, the PIC will direct the aircraft 

to hover in place until line-of-sight is established. 
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EXHIBIT A - Exemption / Waiver Requests 

The regulations from which Geo-Rhea seeks exemption are 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 AND EQUIVALENT LEVEL OF 

SAFETY SHOWINGS 

UNDER APPLICABLE 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: Airworthiness Certificates 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 aircraft 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 these 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 exclusively 

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 the 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 Aircraft. 

The regulation provides: 

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 

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 sUAS will have no 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-inch 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 will 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. 
13

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 particular 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. 

The 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 operations 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 Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there 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 manufacturer’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 public 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 Aircraft Flight Manual in the Aircraft. 

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 combination 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 

Trimble and others the following exemptions to this regulation: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

14 C.F.R. §91.119: Minimum Safe Altitudes. 

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 AGL, 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 not operate at higher than 400 AGL. 
15

The equivalent level of safety will be achieved given the size, weight, and speed of the sUAS, as 

well 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 required. 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 

weighting far more than 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 Altitudes 

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 Section 91.119(c) is needed. 

The equivalent level of safety will be achieved given the size, weight, speed, and material with 

which the respective VTOLs are built. Also, no flight will be taken without the permission of the 

land owner or those who control the 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 associated with these operations will be far less than those currently allowed with 

conventional aircraft operating at or below 500 feet AGL. The low-altitude operations of the 

sUAS technology will facilitate maintaining separate air space between sUAS operations and

conventional aircraft that must comply with Section 91.119. 
16

14 C.F.R. §91.121: Altimeter 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 be 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) During 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 45 minutes 

SkyRanger, of powered flight, which is less than the required reserve for a VFR day flight. GeoRhea 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 achieved 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 the 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 return 

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. 
17

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft 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 certificate. . . . (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 prescribed 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. Maintenance 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 achieved 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 sUAS 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. 
18

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 Visual 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 hazards 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. Work will 

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 District 

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 will 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 the 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 obstacles, 

emergencies, or system anomalies. 
19

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); and 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 Ways (ROW) immediately adjacent to, for the telecommunication, electric utility, 

aggregate/coal, and oil and gas industries.