April 20, 2015

U.S. Department ofTransportation, Docket Management System 1200 NewJersey Ave., SE Washington, DC 20590 Attn: Petition ofGeum 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 of2012 ("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 ofnatural or restored habitat areas adjacentto more managed areas that include pasture or commercial row crops, and areas ofmanaged turfgrass. Access to aerial images will provide large format over-view of property segments allowingfortimely and efficientvisual verification of properties and field boundaries, wildlife movements and management, invasive species verification, tracking, monitoring and management control outcome verification. Monitoringofwetlands, woodlands, and open areas grasslands will be made effective, timely, and less invasive through the use ofan 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 ofsmall unmanned aerial vehicles (i.e., small unmanned aircraftsystems 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 pursuantto Section 333 ofthe Reform Act.

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

For your convenience, this petition is organized as follows: I. Petitioner's Description II. Relevant StatutoryAuthority Ill. Qualification forApproval 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. 14C.F.R. §91.103: Preflight Action.
H. 14C.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. 14C.F.R. §91.203 (a) 

### & (b): Carrying Civil Aircraft Certification and Registration.
M. 14C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b): Maintenance Inspections. VI. Public InterestV
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 ofexperience in video and photographythe Petitionerwould like to add to theirservices aerial video and photography. The Petitioner is well qualified to performthe proposed s-UAS operations. Having over 2years' experience in flying s-UAS recreationally. II. Consistentwith 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: 1-269-760-0484and 1-269-370-0150 Email: jrob@me.com 

### & SteveA@prairiesmoke.com IV. Relevant StatutoryAuthorityThis 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 ofcivil unmanned aircraft systems into the national airspace system" and, under Section 333 ofthat law, directed the Secretary ofTransportation ("FAA Administrator") to considerwhethercertain unmanned aircraft systems mayoperate 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 determinewhich types ofs-UASs do not create a hazard to users ofthe NAS orthe public or pose athreatto 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 proximityto airports and populated areas; and c. Operation ofthe s-UAS within visual line ofsight ofthe operator. d. Ifthe Secretary determines that such vehicles "mayoperate safely in the National Airspace System, the Secretary shall establish requirements forthe safe operation ofsuch 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) (authorizingthe grantof exemptions from a requirement of regulations prescribed pursuantto section 44701(a)±(b) and sections 44702±44716). A party requesting an exemption mustexplain the reasons whythe exemption: (1) would benefitthe public as awhole, and; (2) would not adversely affect safety (or how itwould provide a level ofsafety at least equal tothe existing rules). See 14C.F.R. § 11.81; FAA, Petition for Exemptions.

Ill. Qualification forApproval Under Section 333 ofthe Reform ActThe proposed operations in this petition for exemption qualifyfor expedited approval under Section 333 ofthe Reform Act. Each ofthe statutory criteriaIand other potentially relevant factors are satisfied. The proposed operationswould permitthe use ofsmall 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 ofsafety beyond that existing when fixed or rotorwing aircraft are used to accomplish the same purpose. Petitioner's s-UASs are rotorcraft, weighting 55 orfewer lbs. including payload. (5) They operate, under normal conditions, at aspeed of no morethan 27 knots and have the capabilityto hover, and move in the vertical and horizontal plane simultaneously. (6)Petitioner's ss-UASs will operate in line-of-sight and will operate onlywithin asterile area described in the enclosed Manual. (7)Such operations will insurethatthe s-UAS will"not create a hazard to users ofthe National Airspace System orthe public."

Given the small size ofthe s-UASs involved and the restricted sterile environmentwithin which theywill operate, this petition for exemption falls squarelywithin that zone ofsafety i.e., an equivalent level ofsafety, Page 3in which Congress envisioned thatthe FAA must, by exemption, allow commercial operations ofs-UASs to commence immediately. Also, due tothe 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 ofsafety surroundingthe proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing s-UASs forthe proposed operations, the grant ofthe requested exemptions is also in the public interest. Accordingly, Petitioner respectfully requests thatthe FAA grantthe 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 ofoperational limitations and conditions which will ensure an equivalent or higher level ofsafetyto 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 ofa pilot and/or observer. 3. Maximum total flight time for each operational flightwill be 25 minutes. Flights will be terminated at 25% battery power reserve should that occur priorto 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 pilotwill be awell qualified drone pilotwith the appropriate practice and certification required by the FAA.
7. The s-UAS pilotwill be Pilot in Command (PIC). Ifa pilot certificate holder otherthan 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 onlyoperatewithin a confined "Sterile Area" as defined in the Manual. 9. A briefing will be conducted in regard tothe planned s-UAS operations priorto each day's activities. Itwill be mandatorythat all personnel who will be performing duties within the boundaries ofthe safety perimeter be present forthis briefing. 10. Pilot and Observerwill have been trained in operation ofs-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, orother 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 aflight 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 Administratordecides a requested exemption is in the public interest. Petitioner seeks an exemption from several interrelated provisions of 14C.F.R. Parts 21, 45 and 91 for purposes ofconducting aerial surveys and inspections using s-UAS. Listed below are: (1) the specific sections of 14 C.F.R. forwhich exemption is sought; and (2) the operating procedures and safeguards that Petitioner has established which will ensure a level ofsafety equal to or betterthan the rules from which exemption is sought. 10A. 14 C.F.R. Part 21, Subpart H Airworthiness Certificates & 14C.F.R. § 91.203(a)(1). This petition seeks an exemption from 14C.F.R. Part 21, Subpart 

### H, which establishes the procedural requirements forthe issuance ofairworthiness 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 bythe Petitioner, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirementfor 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 demonstratesthatthe s-UAS operated without an airworthiness certificate, in the restricted environment and underthe conditions proposed will be at least as safe, orsafer, than aconventional rotorcraft operating with an airworthiness certificate withoutthe restrictions and conditions ofthe proposed s-UAS operations. Equivalent Level ofSafety The s-UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within asecured 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, pursuantto the Manual's requirements. Moreover,the FAA will have advance notice ofall operations conducted underthis exemption.

Page 5The s-UAS to be operated hereunder weighs less than 55 lbs. fully loaded, carries neithera pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within asecured area as set out in the Manual. Unlike othercivil aircraft, the proposed operations in this petition for exemption will be controlled and monitored by the operator, pursuanttothe Manual's requirements. These safety enhancements, which already applyto civil aircraft operated in connection with existing inspection operations, provide agreater degree ofsafetytothe public and propertyownersthan conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H Lastly, application ofthese same criteria demonstratesthatthere is no credible threatto national security posed bythe s-UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inabilityto carry a substantial external load.


### B. 14C.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 extentthe Petitioner's s-UASs would otherwise require certification under Part 27, as a rotorcraft, Petitioner airworthiness standards forthe same reasons identified in the exemption request from 14C.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 14C.F.R. §§ 91.9(cL 45.23(b) and 45.27(a). 14C.F.R. § 91.9(cL civil aircraftflight 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 onlythe 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 morethan 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 ofa rotorcraft must display on that rotorcraft horizontallyon both surfaces ofthe cabin, fuselage, boom, ortail the marks required by §45.23. Exemption from§ 45.23(b) is warranted because the s-UAV has no entrance tothe 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 reliefsought by this exemption request, Petitioner requires relieffrom the associated marking and identification requirements of§ 45.27(a) and §91.9(cL which would require compliance with§ 45.23(b) Equivalent Level ofSafety An equivalent level ofsafetyfor exemptionstothe aircraft marking and identification requirements of§§ 91.9(cL 45.23(b) and 45.27(aL will be provided by havingthe UAV marked on its fuselage as required by §45.29(f) where the pilot, observer, and others workingwith the UAV will see the identification ofthe s-UAS as "Experimental." Additionally, Petitionerwill 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. 14C.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 ofan aircraftthat is carrying passengers or propertyfor 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 oremployment; and (2) The aircraft does notcarry passengers or propertyfor 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 pilotto command an aircraft without passengers or property, in connection with business or employment if "[t]the flight is only incidental tothat business or employment."That exception likely does not applyto the proposed operations underthis petition for exemption, as the flights are not incidental tothe 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 requirementthatthe flight be incidental to the business to benefit from the exception. Equivalent Level ofSafety As required bythe Manual, Petitioner's s-UAS operators acting as PIC will hold acommercial and/or private pilot certification and have a rotorcraft rating. Because the s-UAS will notcarry a pilot or passengers, the proposed operations can achieve the equivalent level ofsafetyto§ 61.113 (a) and (b), by requiring the PIC operatingthe s-UAS to have eithera commercial and/or private pilot certification with rotorcraft rating. Unlike aconventional aircraftthat carries the pilot and passengers, the s-UAS is remotely controlled with no livingthing 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 ofsafety provided bythe requirements included in the Manual exceeds that provided by asingle individual holding acommercial pilot's certificate operating aconventional aircraft in accordance with § 61.113 (a) 

### & (b). The risks associated with the operation ofsmall, 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) Forwhich 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 abilityto 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 ofSafetyThe safety related purpose ofthis manual requirement can be equally satisfied by maintainingthe s-UAS flight manual at the ground control pointwhere the pilotflying 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 conditionthatthe s-UAS flight manual be available atthe control point during each operation. The FAA has issued the following exemptions tothis 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 acivil aircraft be in an airworthy condition to be operated. Inasmuch there will be no airworthiness certificate issued forthe s-UAS, should this Page 7exemption be granted, no FAA regulatory standard will existfor determining airworthiness. Equivalent Level of Safety UtilityAerial Services pilots thatwill be flying the s-UAS have over 2years and good safety record. Given the size ofthe s-UAS and the requirements contained in the Manual for maintenance and use ofsafety checklists priorto each flight, an equivalent level ofsafety will be provided. The FAA has issued the following exemptions tothis regulation: Exemption Nos. 

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

### 32827, and 10700. G. 14 C.F.R. §91.103: PreflightAction. 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 forthe s-UAS, an exemption will be needed. Equivalent Level ofSafety An equivalent level ofsafetywill be provided byfollowingthe Aircraft Operations Manual comprehensive preflight checklist. The PIC will take all actions, including reviewing weather, flight battery requirements, landing and takeoffdistances, and aircraft performance data, before initiation offlight. 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 forflight instruction unless that aircraft has fully s-UAS and remotely piloted aircraft, by theirdesign do not have fully functional dual controls. Instead, flight control is accomplished through the use ofacontrol boxthat communicates with the s-UAS via radio communications. Equivalent Level ofSafety Given the size and speed ofthe s-UAS, an equivalent level ofsafe training can still be performed without dual controls because no pilot or passengers are aboard the s-UAS, and all persons will be asafe distance away should the s-UAS experience any difficulties duringflight instruction.The FAA has approved exemptions forflighttraining withoutfully functional dual controls for a number ofaircraft and forflight instruction in experimental aircraft. See Exemption Nos. 5778K 

### & 9862A. I. 14C.F.R. §91.119: Minimum Safe Altitudes. T This petition seeks an exemption from the minimum safe altitude requirements of 14C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes underwhich aircraft may not operate, including 500feet above the surface and awayfrom any person, vessel, vehicle, or structure in non-congested areas. See 14C.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 ofSafety Compared to flight operations with rotorcraftweighting far morethan the maximum 55 lbs. proposed herein, and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft. An equivalent level ofsafetywill 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 withouttheir pre-obtained consent.16 No flightwill be taken withoutthe 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 aircraftthat are subjectto 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 aircraftto maintain cruising altitude orflight level by reference to an altimeterthat is setto the elevation ofthe departure airport or barometric pressure. An exemption is required because the s-UAS does not have a barometric altimeter, but rather aGPS altitude
Page 8read out. Equivalent Level ofSafety An equivalent level ofsafety will be achieved byfollowingthe procedures set forth in the Manual. As prescribed in the Manual, the operatorwill confirm the altitude ofthe launch site shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicatorto 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 forflight in VFR conditions. Section 91.151 states: (a) No person may begin aflight in an airplane underVFR conditions unless (considering wind and forecast weatherconditions) there is enough fuel to fly tothe first point of intended landing and, assuming normal cruising speed (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthatfor at least 45 minutes. The battery poweringthe s-UAS provides approximately 25 minutes ofpowered flight. An exemption from the 30 minute reserve requirement in 14CFR §91.151 is therefore required.

An equivalent level ofsafety can be achieved by limitingflights to 25 minutes or25% 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 notengenderthetype 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 priorexemptions. See e.g. Exemption 10673 (allowing Lockheed Martin Corporation to operate withoutcompliance 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 acivil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate (b) No person may operate acivil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or aspecial flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers or crew. In addition tothe fact that Petitioner is seeking an exemption from the airworthiness load capacity and size does not allow itto carry certification and registration documents; (2) The s-UAS does not have acabin or cockpit entrance atwhich the documents could be displayed; and (3) There are no passengers or crewforwhom the certificates need be displayed. To the extentthese regulations are applicable tothe proposed s-UAS operations, an equivalent level ofsafety will be achieved by keeping these documents at the ground control pointwhere the pilotflying the s-UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample ofotherexceptions 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) (statingthat each owneror operator ofan aircraft as prescribed in subpart Eofthis part and shall between required inspections

... have An exemption tothese regulations is needed because Part 43 and these sections apply onlyto aircraftwith an airworthiness certificate, which the s-UAS will not have. An equivalent level ofsafetywill 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 operatorwill ensure thatthe s-UAS is in working order priorto initiatingflight, perform required maintenance, and keep a log ofany maintenance performed. The operator is the person mostfamiliar 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 operatingfrom no higherthan 400 feetAG L. Moreover, the s-UAS's small size, carrying capacity, and the factthatflight operationswill onlytake place in restricted areas for limited periods oftime, create less risk than the same factors associated with conventional fixed-wing aircraft and rotorcraft performingthe same operation. Public Interest Consistent
With the requirements of 14 C.F.R. §11.81(d), Petitioner offers the following reasons whygrantingthis petition for exemption is in the public interest, i.e., how granting itwould benefitthe public as awhole. Approval ofexemptions allowing commercial operations ofsmall and lightweight s-UAS in the utilityaerial services industry benefits the public as awhole in the followingways: It helps fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act, namely, the FAA Administrator's assessment ofwhethercertain 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-powergeneration inspections and patrols have experienced an exceedingly high number ofaccidents 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 afull size helicopter. The public's interest is furthered by minimizing ecological impact ofan accident and by reducing human exposure to potentially harmful emissions associated with manned aircraft. xAerial surveys are valuable tools for utility-powergeneration inspections. However, problems with safety, cost, statistical integrity, and logistics continue to impede aerial surveys and inspections from conventional manned aircraft. The use ofs-UAS addresses these problems and is a powerful tool for performing awide-range ofapplications. Privacy All flights will occur over Petitioner's property orthe Customer's propertywith the Customer's prior consent and knowledge. Page 10VIII. Federal Register Summary Pursuantto 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: UtilityAerial Services, Inc. seeks an exemption from the following rules: 14CFR 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); 14CFR 91.9(b)(2); 14CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) 

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

### & (b). Approval ofexemptions allowing commercial operations ofsmall and lightweight unmanned aircraft ("s-UAS") in the utility-power inspection industrywill enhance safety by reducing risk. Conventional operations in this industry using rotorcraft orfixed-wing aircraft presentthe risks associated with vehicles thatweigh in the neighborhood ofseveral 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 fewerthan 55 lbs. and powered by batteries eliminatesvirtually all ofthat risk, given the reduced mass and lack of combustible fuel carried on board. The s-UAS is transported, notflow, tothe designated survey area and set up. The s-UAS carries no passengers or crew and, therefore, does notexpose them tothe risks associated with manned aircraftflights. The operation ofsmall s-UASs, weighting less than 55 lbs., provides an equivalent level ofsafety and thus supports the grant ofthe exemptions requested herein, including exemptingthe applicant from the requirements of Part 21 and allowing commercial operations. These lightweight s-UASs operate at slow speeds, close tothe ground, and in asterile environment. As a result, they are far safer than conventional aerial survey ofgolfcourse and real estate than op Conclusion Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of2012 size, weight, speed, operating capabilities, proximityto airports and populated areas, and operation within visual line ofsight and national security2provides more than adequatejustification forthe grantofthe requested exemptions allowing commercial operation ofGeum 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 linktotheirfly safe program. http:/ /flysafe.dji.com/ And the linkto theirspecs page: http:/ /www.dji.com/product/phantom-3/spec The manual has not been released when itdoes, itwill be posted online. Ifadditional information is required, or ifyou have any questions regarding this Petition for Exemption, please contactthe 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