April 20, 2015 

U.S. Department of Transportation, Docket Management System 

1200 New Jersey Ave., SE Washington, DC 20590 

Attn: Petition of Geum Services, Inc. for Exemption Pursuant to Section 333 of the FAA Reform Act 

To Whom It May Concern: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("Reform Act") and 14 C.F.R. Part 

11, Geum Services, Inc. ("Petitioner"), assists in the management of large property holdings. These 

properties can be a mixture of natural or restored habitat areas adjacent to more managed areas that include 

pasture or commercial row crops, and areas of managed turf grass. Access to aerial images will provide large 

format over-view of property segments allowing for timely and efficient visual verification of properties and 

field boundaries, wildlife movements and management, invasive species verification, tracking, monitoring and 

management control outcome verification. Monitoring of wetlands, woodlands, and open areas grasslands 

will be made effective, timely, and less invasive through the use of an aerial platform with high-resolution 

optical capabilities. Geum services also will provide aerial photography and aerial video services, for golf 

courses, real estate realtors and for additional photography and video needs such for personal events such 

weddings, etc. Geum Services hereby applies for an exemption from Federal Aviation Regulations ("FARs") 

identified below, to allow _commercial operation of small unmanned aerial vehicles (i.e., small unmanned 

aircraft systems or "s-UAS"). 

This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed Geum 

Services, Inc. Manual 1 ("Manual"), the s-UAS manufacturer's operations and/or instructions manual ("Aircraft 

Operations Manual"), and any other requirements established by the FAA pursuant to Section 333 of the 

Reform Act. 

1 Petitioner submits this Manual as a Confidential document under 14 C.F.R. § 11.35(b), as the entire Manual 

contains confidential commercial and proprietary information that the Petitioner has not and will not share 

with others. The Manual contains operating conditions and procedures that are not available to the public and 

are protected from release under the Freedom of information Act 5 U.S.C. § 552 

For your convenience, this petition is organized as follows: 

I. Petitioner's Description 

II. Relevant Statutory Authority 

Ill. Qualification for Approval Under Section 333 of the 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. 

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J 

I 

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

D. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

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

F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness. 

G. 14 C.F.R. § 91.103: Preflight Action. 

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

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

J. 14 C.F.R. § 91.121 Altimeter Settings. 

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

L. 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration. 

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

VI. Public Interest V 

II. Privacy 

VIII. Federal Register Summary 

IX. Conclusion April 20, 2015 

I. Petitioner's Description- Petitioner is affiliated with Geum Services, Inc. Geum Services, In 

building upon years of experience in video and photography the Petitioner would like to add to 

their services aerial video and photography. The Petitioner is well qualified to perform the 

proposed s-UAS operations. Having over 2 years' experience in flying s-UAS recreationally. 

II. Consistent with the requirements of 14 C.F.R. § 11.81(a), Petitioner provides the following 

information in support of its petition for exemption: 

Ill. The name and address of the Petitioner is: Geum Services, Inc. 

Attn: Steve Allen and Jerry Robinson and PO Box 035 Richland, Ml 49083. 

Phone: 1-269-760-0484 and 1-269-370-0150 Email: jrob@me.com & 

SteveA@prairiesmoke.com 

IV. Relevant Statutory Authority This petition for exemption is submitted to fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act. In the Reform Act, Congress directed the 

FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national 

airspace system" and, under Section 333 of that law, directed the Secretary of Transportation 

("FAA Administrator") to consider whether certain unmanned aircraft systems may operate 

safely in the National Airspace System ("NAS") before completion of the rulemaking required 

under Section 332 of the Reform Act.3 

V. In making this determination, the Secretary is required to determine which types of s-UASs do 

not create a hazard to users of the NAS or the public or pose a threat to national security in 

light of the following: Reform Act§ 333{a). 

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a. The s-UAS's size, weight, speed, and operational capability; 

b. Operation of the s-UAS in close proximity to airports and populated areas; and 

c. Operation of the s-UAS within visual line of sight of the operator. 

d. If the Secretary determines that such vehicles "may operate safely in the National Airspace 

System, the Secretary shall establish requirements for the safe operation of such aircraft in 

the National Airspace System" (Emphasis added) 

e. In addition, the FAA Administrator has general authority to grant exemptions from its safety 

regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 44701(f) (authorizing the grant of 

exemptions from a requirement of regulations prescribed pursuant to section 44701(a)±(b) 

and sections 44702±44716). 

A party requesting an exemption must explain the reasons why the exemption: 

(1) would benefit the public as a whole, and; 

(2) would not adversely affect safety (or how it would provide a level of safety at least equal to the existing 

rules). See 14 C.F.R. § 11.81; FAA, Petition for Exemptions. 

Ill. Qualification for Approval Under Section 333 of the Reform Act The proposed operations in this petition 

for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory 

criteria I and other potentially relevant factors are satisfied. 

The proposed operations would permit the use of small and relatively inexpensive s-UAS under controlled 

conditions in airspace that is: 

(1) limited; 

(2) predetermined; 

(3) controlled as to access, and; 

(4) would provide an increased level of safety beyond that existing when fixed or rotor wing aircraft are used 

to accomplish the same purpose. Petitioner's s-UASs are rotorcraft, weighting 55 or fewer lbs. including 

payload. 

(5) They operate, under normal conditions, at a speed of no more than 27 knots and have the capability to 

hover, and move in the vertical and horizontal plane simultaneously. 

(6)Petitioner's s s-UASs will operate in line-of-sight and will operate only within a sterile area described in the 

enclosed Manual. 

(7)Such operations will insure that the s-UAS will"not create a hazard to users of the National Airspace System 

or the public." 

Given the small size of the s-UASs involved and the restricted sterile environment within which they will 

operate, this petition for exemption falls squarely within that zone of safety i.e., an equivalent level of safety, 

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in which Congress envisioned that the FAA must, by exemption, allow commercial operations of s-UASs to 

commence immediately. Also, due to the size of the s-UASs and the restricted areas in which the ss-UASs will 

operate, approval of the application presents no national security issue. 

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced 

emissions associated with allowing s-UASs for the proposed operations, the grant ofthe requested 

exemptions is also in the public interest. Accordingly, Petitioner respectfully requests that the FAA grant the 

requested exemption without delay. 

IV. Description of Proposed Operations 

The enclosed Manual describes, in detail, the policies and procedures for Petitioner's proposed s-UAS 

operations. To assist the FAA in its safety assessment of Petitioner's proposed s-UAS operations, below is a 

summary of operational limitations and conditions which will ensure an equivalent or higher level of safety to 

operations conducted under current regulatory guidelines: 

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

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

3. Maximum total flight time for each operational flight will be 25 minutes. Flights will be terminated at 25% 

battery power reserve should that occur prior to the 25 minute limit. 4 

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

5. Minimum crew for each operation will consist of the s-UAS Pilot. 

6. The s-UAS pilot will be a well qualified drone pilot with the appropriate practice and certification required 

by the FAA. 

7. The s-UAS pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the s-UAS Pilot is 

present and possesses the necessary PIC qualifications, that person can also be designated as PIC. 

8. The s-UAS will only operate within a confined "Sterile Area" as defined in the Manual. 

9. A briefing will be conducted in regard to the planned s-UAS operations prior to each day's activities. It will 

be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter 

be present for this briefing. 

10. Pilot and Observer will have been trained in operation of s-UAS generally and will have received up-to-date 

information on the particular s-UAS to be operated, as required in the Manual. 

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

12. Written and/or oral permission from the relevant property holders will be obtained. 

13. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire, or other appropriate governmental agencies. 

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14. If the s-UAS loses communications or loses its GPS signal, the s-UAS is equipped with advanced safety 

features that will allow the s-UAS to automatically return to a predetermined location. 

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

VI. Regulations From Which Exemption Is Requested 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. By its terms, this 

statutory authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including 

s-UASs, from its safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. 

Petitioner seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45 and 91 for 

purposes of conducting aerial surveys and inspections using s-UAS. 

Listed below are: 

(1) the specific sections of 14 C.F.R. for which exemption is sought; and 

(2) the operating procedures and safeguards that Petitioner has established which will ensure a level of safety 

equal to or better than the rules from which exemption is sought. 10 A. 14 C.F.R. Part 21, Subpart H 

Airworthiness Certificates & 14 C.F.R. § 91.203(a)(1). 

This petition seeks an exemption from 14 C.F.R. Part 21, Subpart H, which establishes the procedural 

requirements for the issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a) 

(1). Given the size and limited operating area associated with the s-UAS to be utilized by the Petitioner, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform 

Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas 

of the particular s-UAS. 

In all cases, an analysis of these criteria demonstrates that the s-UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, 

than a conventional rotorcraft operating with an airworthiness certificate without the restrictions and 

conditions of the proposed s-UAS operations. 

Equivalent Level of Safety 

The s-UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set 

out in the Manual. Unlike other civil aircraft, the proposed operations in this petition for exemption will be 

controlled and monitored by the operator, pursuant to the Manual's requirements. Moreover, the FAA will 

have advance notice of all operations conducted under this exemption. 

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The s-UAS to be operated hereunder weighs less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured 

area as set out in the Manual. Unlike other civil aircraft, the proposed operations in this petition for exemption 

will be controlled and monitored by the operator, pursuant to the Manual's requirements. These safety 

enhancements, which already apply to civil aircraft operated in connection with existing inspection 

operations, provide a greater degree of safety to the public and property owners than conventional 

operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H 

Lastly, application of these same criteria demonstrates that there is no credible threat to national security 

posed by the s-UAS, due to its size, speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

B. 14 C.F.R. Part 27: Airworthiness Standards: Normal Category Rotorcraft. 14 C.F.R. Part 27 sets forth the 

procedural requirements for airworthiness certification of normal category rotorcraft. To the extent the 

Petitioner's s-UASs would otherwise require certification under Part 27, as a rotorcraft, Petitioner 

airworthiness standards for the same reasons identified in the exemption request from 14 C.F.R. Part 21, 

Subpart H. 

C. Aircraft Marking and Identification Requirements: 14 C.F.R. §§ 91.9(cL 45.23(b) and 45.27(a). This petition 

seeks an exemption from the aircraft marking and identification requirements of 14 C.F.R. §§ 91.9(cL 45.23(b) 

and 45.27(a). 14 C.F.R. § 91.9(cL civil aircraft flight manual, marking, and placard requirements, provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with part 

45 of this chapter. 14 C.F.R. § 45.23(bL Markings of the Aircraft, states: When marks include only the Roman 

capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft 

or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters 13 not less than 2 inches nor more than 6 inches high, 

the words "limited/' "restricted/' "light-sport/' "experimental/' or "provisional/' as applicable. 14 C.F.R. § 

45.27(aL Rotorcraft, states: Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by §45.23. Exemption from§ 45.23(b) is 

warranted because the s-UAV has no entrance to the cabin, cockpit, or pilot station on which the word 

"Experimental" can be placed. Moreover, given the size of the s-UAV, two-inch lettering would be impossible. 

The word "Experimental" will be placed on the fuselage in compliance with§ 45.29(f). Given the nature of the 

specific relief sought by this exemption request, Petitioner requires relief from the associated marking and 

identification requirements of§ 45.27(a) and § 91.9(cL which would require compliance with§ 45.23(b) 

Equivalent Level of Safety 

An equivalent level of safety for exemptions to the aircraft marking and identification requirements of§§ 

91.9(cL 45.23(b) and 45.27(aL will be provided by having the UAV marked on its fuselage as required by 

§45.29(f) where the pilot, observer, and others working with the UAV will see the identification of the s-UAS as 

"Experimental." Additionally, Petitioner will ensure compliance with any requests of s-UAS marking by the 

FAA. The FAA has issued the following exemptions to the aircraft marking requirements of§ 45.23(b): 

Exemptions Nos. 10700, 8738, 10167 and 10167A. D. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and 

Limitations: Pilot in Command. This petition seeks an exemption from the private pilot privileges and 

limitations of§ 61.113 (a) & (bL which states: Private Pilot Privileges and Limitations: Pilot in Command. (a) 

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Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate 

may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; 

nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, 

for compensation or hire, act as pilot in command of an aircraft in connection with any business or 

employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. Section 61.113(a) limits 

private pilots to being in command of non-commercial flights. Section 61.113(b)(1) provides an exception that 

allows a private pilot to command an aircraft without passengers or property, in connection with business or 

employment if "[t]the flight is only incidental to that business or employment." That exception likely does not 

apply to the proposed operations under this petition for exemption, as the flights are not incidental to the 

proposed aerial surveys and inspections but rather essential to it. Accordingly, this petition seeks an 

exemption to§ 61.113(a)'s commercial limitation and/or§ 61.113(b)(1)'s requirement that the flight be 

incidental to the business to benefit from the exception. Equivalent Level of Safety As required by the Manual, 

Petitioner's s-UAS operators acting as PIC will hold a commercial and/or private pilot certification and have a 

rotorcraft rating. Because the s-UAS will not carry a pilot or passengers, the proposed operations can achieve 

the equivalent level of safety to§ 61.113 (a) and (b), by requiring the PIC operating the s-UAS to have either a 

commercial and/or private pilot certification with rotorcraft rating. Unlike a conventional aircraft that carries 

the pilot and passengers, the s-UAS is remotely controlled with no living thing on board. Moreover, the area of 

operation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in 

the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by 

a single individual holding a commercial pilot's certificate operating a conventional aircraft in accordance with 

§ 61.113 (a) & (b). The risks associated with the operation of small, lightweight s-UAS are diminished from the 

level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing the 

proposed operations in this petition for exemption with a private pilot as the PIC exceeds the present level of 

safety achieved by§ 61.113 (a) & (b). E. 14 C.F.R. § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft. This 

petition seeks an exemption from the flight manual requirements of 14 C.F.R. § 91.9(b)(2), which states: (b) No 

person may operate a U.S.-registered civil aircraft2 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 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 its size, configuration, and load capacity, the s-UAS 

has no ability to carry such a manual on the aircraft, not only because there is no pilot on board, but because 

there is simply no room or capacity to carry such an item on the aircraft. Equivalent Level of Safety The safety 

related purpose of this manual requirement can be equally satisfied by maintaining the s-UAS flight manual at 

the ground control point where the pilot flying the s-UAS will have immediate access to it. 

Accordingly, Petitioner requests an exemption from§ 91.9(b )(2)'s flight manual requirements, on the 

condition that the s-UAS flight manual be available at the control point during each operation. The FAA has 

issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

95658, 10167, 10167A, 10602,32827, and 10700. F. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness. This 

petition seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be in an airworthy 

condition to be operated. Inasmuch there will be no airworthiness certificate issued for the s-UAS, should this 

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exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Equivalent Level of 

Safety Utility Aerial Services pilots that will be flying the s-UAS have over 2 years and good safety record. Given 

the size of the s-UAS and the requirements contained in the Manual for maintenance and use of safety 

checklists prior to each flight, an equivalent level of safety will be provided. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 

10602, 32827, and 10700. G. 14 C.F.R. § 91.103: Preflight Action. 

This petition seeks an exemption from§ 91.103, which requires a PIC to become familiar with specific 

information before each flight, including information contained in the FAA approved Flight Manual on board 

the aircraft. Inasmuch as an FAA approved flight manual will not be provided for the s-UAS, an exemption will 

be needed. 

Equivalent Level of Safety An equivalent level of safety will be provided by following the Aircraft Operations 

Manual comprehensive preflight checklist. The PIC will take all actions, including reviewing weather, flight 

battery requirements, landing and takeoff distances, and aircraft performance data, before initiation of flight. 

H. 14 C.F.R. § 91.109(a): Flight Instruction. This petition seeks an exemption from 14 C.F.R. § 91.109(aL which 

provides that person may operate a civil aircraft (except a manned free balloon) that is being used for flight 

instruction unless that aircraft has fully s-UAS and remotely piloted aircraft, by their design do not have fully 

functional dual controls. Instead, flight control is accomplished through the use of a control box that 

communicates with the s-UAS via radio communications. Equivalent Level of Safety Given the size and speed 

of the s-UAS, an equivalent level of safe training can still be performed without dual controls because no pilot 

or passengers are aboard the s-UAS, and all persons will be a safe distance away should the s-UAS experience 

any difficulties during flight instruction. The FAA has approved exemptions for flight training without fully 

functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See 

Exemption Nos. 5778K & 9862A. I. 14 C.F.R. § 91.119: Minimum Safe Altitudes. T 

This petition seeks an exemption from the minimum safe altitude requirements of 14 C.F.R. § 91.119. Section 

91.119 prescribes the minimum safe altitudes under which aircraft may not operate, including 500 feet above 

the surface and away from any person, vessel, vehicle, or structure in non-congested areas. See 14 C.F.R. § 

91.119(c). Section§ 91.119(d)(1) allows for a hazard to persons helicopter complies with any routes or 

altitudes specifically prescribed for helicopters. 

Equivalent Level of Safety Compared to flight operations with rotorcraft weighting far more than the 

maximum 55 lbs. proposed herein, and the lack of flammable fuel, any risk associated with these operations is 

far less than those presently presented with conventional aircraft. An equivalent level of safety will be 

achieved given the size, weight, speed of the s-UAS as well as the location where it is operated. As set forth in 

the Manual, the s-UAS will be operated in a restricted area, where buildings and people will not be exposed to 

operations without their pre-obtained consent.16 No flight will be taken without the permission of the 

property owner and/or local officials. Because of the advance notice to the property owner and participants, 

all affected individuals will be aware of the planned flight operations as set forth in the Manual. Furthermore, 

by operating at such lower altitudes, the s-UAS will not interfere with other aircraft that are subject to the 

minimum safe altitude regulations. J. 14 C.F.R. § 91.121 Altimeter Settings. This petition seeks an exemption 

from 14 C.F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight 

level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. 

An exemption is required because the s-UAS does not have a barometric altimeter, but rather a GPS altitude 

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read out. Equivalent Level of Safety An equivalent level of safety will be achieved by following the procedures 

set forth in the Manual. As prescribed in the Manual, the operator will confirm the altitude of the launch site 

shown on the GPS altitude indicator before flight. Moreover, the PIC will use the GPS altitude indicator to 

constantly monitor the s-UASs height, thus ensuring operation at safe altitudes. K. 14 C.F.R. § 91.151(a): Fuel 

Requirements for Flight in V FR Conditions. 

This petition seeks an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR conditions. 

Section 91.151 states: (a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed 

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. The battery powering the s-UAS provides approximately 

25 minutes of powered flight. An exemption from the 30 minute reserve requirement in 14 CFR §91.151 is 

therefore required. 

An equivalent level of safety can be achieved by limiting flights to 25 minutes or 25% of battery power, 

whichever happens first. This restriction would be more than adequate to return the s-UAS to its planned 

landing zone from anywhere within its limited operating area. Operation of the s-UAS with less than 30 

minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was intended to alleviate 

given the size and speed of the small s-UAS. Moreover, operation will be limited to controlled areas where 

only people and property owners, or official representatives who have signed waivers will be allowed. 

This request for exemption falls within the scope of prior exemptions. See e.g. Exemption 10673 (allowing 

Lockheed Martin Corporation to operate without compliance with§ 91.151 (a)); see also Exemptions 2689F, 

5745, 10673, and 10808. L. 14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration. 

This petition seeks an exemption from civil aircraft certification and registration requirements of 14 C.F.R. § 

91.203 (a) and (b). The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may 

operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness 

certificate 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

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. In addition to the fact that Petitioner is seeking an 

exemption from the airworthiness load capacity and size does not allow it to carry certification and 

registration documents; 

(2) The s-UAS does not have a cabin or cockpit entrance at which the documents could be displayed; and 

(3) There are no passengers or crew for whom the certificates need be displayed. 

To the extent these regulations are applicable to the proposed s-UAS operations, an equivalent level of safety 

will be achieved by keeping these documents at the ground control point where the pilot flying the s-UAS will 

have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative 

sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 

10700. M. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b): Maintenance Inspections. 

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This petition seeks an exemption from the maintenance inspection requirements of 14 C.F.R. §§ 91.405(a); 

91.407(a)(1); 91.409(a)(2); 91.417 (a) & (b). These regulations specify maintenance and inspection standards in 

reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an 

aircraft as prescribed in subpart E of this part and shall between required inspections ... have 

An exemption to these regulations is needed because Part 43 and these sections apply only to aircraft with an 

airworthiness certificate, which the s-UAS will not have. 

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the Aircraft Operations Manual as referenced in the Manual.19 As provided in the Manual, 

the operator will ensure that the s-UAS is in working order prior to initiating flight, perform required 

maintenance, and keep a log of any maintenance performed. The operator is the person most familiar with 

the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. If mechanical issues arise, the s-UAS can land immediately and will be operating from no higher than 

400 feet AG L. 

Moreover, the s-UAS's small size, carrying capacity, and the fact that flight operations will only take place in 

restricted areas for limited periods of time, create less risk than the same factors associated with conventional 

fixed-wing aircraft and rotorcraft performing the same operation. 

Public Interest Consistent 

With the requirements of 14 C.F.R. §11.81(d), Petitioner offers the following reasons why granting this 

petition for exemption is in the public interest, i.e., how granting it would benefit the public as a whole. 

Approval of exemptions allowing commercial operations of small and lightweight s-UAS in the utility aerial 

services industry benefits the public as a whole in the following ways: 

It helps fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act, namely, the FAA 

Administrator's assessment of whether certain s-UAS may operate safely in the National Airspace System 

before completion of the rulemaking required under Section 332 of the Reform Act. 

The operation significantly improves safety and reduces risk by alleviating human exposure to danger 

associated with current aerial survey and inspection methods, namely, full size helicopters. Manned 

helicopters performing utility-power generation inspections and patrols have experienced an exceedingly high 

number of accidents and fatalities. 

Petitioner's s-UASs are battery powered and create no emissions. If Petitioner's s-UAS crashes, there is no fuel 

to ignite and explode. Any impact of Petitioner's lightweight s-UASs is, obviously, far less than a full size 

helicopter. The public's interest is furthered by minimizing ecological impact of an accident and by reducing 

human exposure to potentially harmful emissions associated with manned aircraft. x Aerial surveys are 

valuable tools for utility-power generation inspections. However, problems with safety, cost, statistical 

integrity, and logistics continue to impede aerial surveys and inspections from conventional manned aircraft. 

The use of s-UAS addresses these problems and is a powerful tool for performing a wide-range of applications. 

Privacy 

All flights will occur over Petitioner's property or the Customer's property with the Customer's prior consent 

and knowledge. 

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VIII. Federal Register Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the FEDERAL REGISTER, 

should it be determined that publication is needed: Utility Aerial Services, Inc. seeks an exemption from the 

following rules: 14 CFR Part 21, Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 C.F.R. § 61.113 (a) & (b); 14 CFR 

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

14 CFR 91.203 (a) & (b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409(a)(2); 14 CFR 91.417 (a) & (b). 

Approval of exemptions allowing commercial operations of small and lightweight unmanned aircraft ("s-UAS") 

in the utility-power inspection industry will enhance safety by reducing risk. Conventional operations in this 

industry using rotorcraft or fixed-wing aircraft present the risks associated with vehicles that weigh in the 

neighborhood of several thousand pounds and carrying large amounts of fuel. Such aircraft must fly to and 

from the survey or inspection location and operate at low altitudes. In contrast, a s-UAS weighing fewer than 

55 lbs. and powered by batteries eliminates virtually all of that risk, given the reduced mass and lack of 

combustible fuel carried on board. The s-UAS is transported, not flow, to the designated survey area and set 

up. The s-UAS carries no passengers or crew and, therefore, does not expose them to the risks associated with 

manned aircraft flights. The operation of small s-UASs, weighting less than 55 lbs., provides an equivalent level 

of safety and thus supports the grant of the exemptions requested herein, including exempting the applicant 

from the requirements of Part 21 and allowing commercial operations. These lightweight s-UASs operate at 

slow speeds, close to the ground, and in a sterile environment. As a result, they are far safer than conventional 

aerial survey of golf course and real estate than op 

Conclusion 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 size, weight, speed, operating 

capabilities, proximity to airports and populated areas, and operation within visual line of sight and national 

security2provides more than adequate justification for the grant of the requested exemptions allowing 

commercial operation of Geum Services, conducted with fixed-wing aircraft or helicopters. 

Manuals and Specifications: 

- DJI Phantom 2 Manual can be found here: http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Pius_User_Manual_v1.8_en.pdf 

DJI Phantom 3 is expected to be released by May 1, 2015. Here the link to their fly safe program. http:/ /flysafe.dji.com/ 

And the link to their specs page: http:/ /www.dji.com/product/phantom-3/spec The manual has not been released 

when it does, it will be posted online. 

If additional information is required, or if you have any questions regarding this Petition for Exemption, please 

contact the undersigned Jerry Robinson, 269-760-0484 or Steve Allen, Geum Services President at: 269-370-

0150. 

Jerry obinson 

jrob@me.com 

269-760-0484 

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