ACI_201501 14 _333 

### January 2015 2 

### TABLE OF CONTENTS

3. List of Abbreviation s 4. Applicant Information /UAV Pilot Information



### SECTION I

– INTRODUCTION AND BACKGROUND INFORMATION

5. Introduction

6. GeoStar sUAS Public Operations in 2014

8

. Intended Section 333 Operational Areas

8. GeoStar sUAS Imagery Product Samples

10. Specific Sections from 14 CFR Sought for Exemption

11. Review of Section 333 Conditions



### SECTION II

– THE GEOSTAR sUAS DESCRIPTION AND PROPOSED OPERATIONS

12. GeoStar UAV Dimension and Weights

13. GeoStar UAV Operating Speeds

14. GeoStar sUAS Description and Operational Capabilities

- General

- Command and Control

- GeoStar UAV Power Scheme

- Flight Profile and Endurance

- GeoStar sUAS Systems Redundancy

- GeoStar sUAS Lost Link Failsafe Descriptions



### - GeoStar sUAS General Operating Parameters

- GeoStar sUAS

– Operational Scenarios

SECTION III

- SPECIFIC CFR EXEMPTION REQUESTS & SUPPORTING EXPLANATIONS

31. 14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Certifications Required

33. 14 CFR § 45.23 Display of marks; general. 14 CFR § 45.25 Location of marks on fixed

- wing aircraft.

14 CFR § 45.29 Size of marks.

34. 14 CFR § 61.113 Private Pilot Privileges and Limitations: Pilot In Command 14 CFR § 61.133 Commercial Pilot Privileges and Limitations.

35. 14 CFR § 91.7 (a) Civil Aircraft Airworthiness 14 CFR § 91.9 (b)(2) Civil Aircraft Flight Manual in the Aircraft

36. 14 CFR § 91.109(a) Flight Instruction 14 CFR § 91.121 Altimeter Settings

37. 14 CFR § 91.151 (a)(1) Fuel Requirements for Flight in VFR Conditions.

42. 14 CFR § 91.207 (a)(1) Emergency Locator Transmitters (ELTs) 14 CFR § 91.307 (a) Parachutes and Parachuting

43. 14 CFR § 91.405 (a) Maintenance Required 14 CFR § 91.407 (a)(1) Operation After Maintenance, Preventative, Rebuilding or Alteration 14 CFR § 91.409(a) Inspections 14 CFR § 91.417 (a)(b) Maintenance Records



### SECTION IV

- SUMMARY STATEMENTS

44. Equivalent Safety

44. Public Benefit

46. Summary for the Public RegisterACI_201501 14 _333 

### January 2015 3 

### List of Abbreviations

AC Alternating Current

AGL Above Ground Level

ATC Air Traffic Control

CFR Code of Federal Regulations

COA Certificate of Waiver or Authorization

CTAF Common Traffic Advisory Frequency

ELT Emergency Locator Transmitter

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GIS Geospatial Information System

GCS Ground Control Station

GMRS General Mobile Radio S ervice m

GPS Global Positioning System

INS Inertial Navigation System

mAh Milli

- Amp Hours

NAS National Airspace System

PIC Pilot in Command

RC Radio Control

RTL Return to Launchpoint

sUAS Small Unmanned Aerial System

TCI Telemet ry Control Interface

UAV Unmanned Aerial Vehicle

UAS Unmanned Aerial System

VDC Volts Direct Current

VFR Visual Flight Rules

VHF Very High FrequencyACI_201501 14 _333 

### January 2015 4 

### Applicant Contact Information:

Timothy J. Briggs AeroLogix Consulting Inc.

101 1 st 

### St SE

New Prague, MN 56071 (952) 334

- 1801 timb@aerologixmn.com

UAV Pilot Information

Timothy Joseph Briggs

Private Pilot Certificate

Certificate Number: 3518562

A SEL, Tail Dragger, Complex, High Performance endorsements.

Medical: Class II, October 2014

ASEL Time: 880 hours

US Navy Sensor Operator Flight Time (1983

- 2005)

P

- 3 Orion, S

- 3 Viking

Total Time 4000+ hours

US Army Contract Sensor Operator Flight Time (2007

- 2015)

Shorts 360 Beech King Air 350

Total Time 3500+ Hours

Fixed Wing Radio Control Experien ce 30+ Years

GeoStar UAV Flight Time 14 flights, 3.3 hours total time in typeACI_201501 14 _333 

### January 2015 5 

### SECTION I

– INTRODUCTION AND BACKGROUND INFORMATION

Introduction

AeroLogix Consulting Inc. (“AeroLogix ”) is the designer, builder and the operator of the GeoStar sUAS aerial imaging

system. The system is capable of creating high resolution geospatial (“GIS”) imagery and engineering grade survey products . The

heart of the system is the GeoStar UAV, a semi

- autonomous fixed wing aircraft with electric power and a payloa d capacity exceeding

10 pounds. AeroLogix currently operates the GeoStar sUAS as a public aircraft in partnership with Le Sueur County, Minnesota

under FAA Certificate of Waiver or Authorization (COA) , 2014

- CSA

- 35. AeroLogix prepared and submitted all CO A application

requirements and documentation on behalf of Le Sueur County. COA 2014

- CSA

- 35 is included for your reference to this application.

AeroLogix is seeking exemption s under the provisions of Section 333 of the FAA Modernization and Reform Act of 2012 (“The

Reform Act”) to commercially operate additional GeoStar UAV airframes to multiple public and private customers. AeroLogix seeks

to operate the identical sUAS system in similar operational and airspace conditions as previously vetted and approved in COA 2014

-

CSA

- 35.

COA 2014

- CSA

- 35 Cover PageACI_201501 14 _333 

### January 2015 6 

### GeoStar sUAS Public Operations in 2014

T he AeroLogix/Le Sueur County partnership w as awarded one of Minnesota’ s first and largest public

- use COAs, 2014

- CSA

35

. FAA authorization was granted on 25 August, 2014 to begin operations of the GeoStar sUAS throughout most of Le Sueur

County in Class E and G airspace . Except for five densely populated towns and two airport areas, all of rural Le Sueur County was

granted authorization for GeoStar sUAS operations.

Le Sueur County Depicted on Twin Cities Sectional Chart

AeroLogix/Le Sueur County Authorized GeoStar sUAS Operating Areas

( all white and magenta are as are authorized)ACI_201501 14 _333 

### January 2015 7 Flight operations began in early September 2014 and continued without incident through late November 2014 when snow cover

pre vented further aerial surveys. During that time, 14 GeoStar missions were safely conducted from multiple locations in Le Sueur

County. The GeoStar UAV met or exceeded all design and performance goals and the program was well received by the general

public and local press. 1 ,2,3 AeroLogix and Le Sueur County i ntend to resume regular operations under COA 2014

- CSA

- 35 in the

spring of 2015 in various l ocations within Le Sueur County to survey agricultural ditches and to provide imagery and engineering

products for other county civil engineering projects

.

GeoStar UAV

The GeoStar UAV saw immediate success as a safe and stabl e aerial photography platform. It was quickly demonstrated

how AeroLogix and the GeoStar s UA S were capable of creating high resolution geospatial (“ GIS ”) im agery and engineering grade

survey products

, at a fractio n of the cost of conventional providers. The Le Sueur County program and the products that were created

generated immediate interest among local GIS users and civil engineering professionals. T he following institutions have expressed

interest and/or directly request ed AeroLogix and GeoStar sUAS services :

- US Department of Agriculture/University of Minnesota clover crop research project.

- US Fish and Wildlife Service

- Minnesota Department of Transportation (3 projects)

- Minnesota Department of Soil and Water

- Scott County, Ravine Survey

- Dakota County, Vermillion River Survey

- Minnesota State University Mankato

, GIS Department

- University of Minnesota, Aerospace Engineering Dept., Graduate Student Program.

1: Man kato Free Press 03 December, 2014, “Drone Mapping Shows Promise”; http://www.mankatofreepress.com/news/local_news/drone

- photography

- shows

- promise/article_74b585a0

- 1b2a

- 5d25

- 9125

- fc1e6fe3a662.html

2 : Minneapolis Star Tribune 26 October

, 2014, “Look Up In The Sky ” ; http://www.startribune.com/local/280418882.html

3: Mankato Free Press, 28 September 2014, “Le Sueur County To Pioneer Drone Mapping” http://www.mankatofreepress.com/news/local_news/le

- sueur

- county

- to

- pioneer

- drone

- mapping/article_f14b1b3a

- 292b

- 5 0c2

- a8ce

- 8649e86d8777.htmlACI_201501 14 _333 

### January 2015 8 

### Intended Section 333 Operational Areas

AeroLogix seeks to commercially operate the GeoStar sUAS under a Section 333 exemption in rural areas, generally in Class

G and Class E airspace. Initial commercial operations are ant icipated in the rural sections of various counties in southern Minnesota.

Further operations in other parts of Minnesota and into other states are expected to follow. AeroLogix expects to file speci fic COA

requests for operating airspace as new projects are contracted. Detailed descriptions of proposed operational parameters are in Section

II of this document under: “ GeoStar sUAS General Operating Parameters ”



### GeoStar sUAS Imagery Product Samples

Sample AeroLogix/GeoStar GIS Imagery

– Le Sueur County, MNACI_201501 14 _333 

### January 2015 9 AeroLogix/GeoStar 3

- D Terrain Model Example

– Ditch 34 in Le Sueur County

Sample Digital Elevation Model

– Le Sueur County, MNACI_201501 14 _333 

### January 2015 10 

### Specific Sections From 14 CFR Sought For Exemption

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Certifications Required 14 CFR § 45.23 Display of marks; general. 14 CFR § 45.25 Location of marks on fixed

- wing aircraft.

14 CFR § 45.29 Size of marks. 14 CFR § 61.113 Private Pilot Privileges and Limitations: Pilot In Command 14 CFR § 61.133 Commercial Pilot Privileges and Limitations. 14 CFR § 91.7 (a) Civil Aircraft Airworthiness 14 CFR § 91.9 (b)(2) Civil Aircraft Flight Manual in the Aircraft 14 CFR § 91.121 Altimeter Settings 14 CFR § 91.151 (a)(1) Fuel Requirements for Flight in VFR Conditions. 14 CFR § 91.207 (a)(1) Emergency Locator Transmitters (ELTs). 14 CFR § 91.307 (a) Parachutes and Parachuting 14 CFR § 91.405 (a) Maint enance Required 14 CFR § 91.407 (a)(1) Operation After Maintenance, Preventative, Rebuilding or Alteration 14 CFR § 91.409 (a) (1)(2) Inspections 14 CFR § 91.417 (a)(b) Maintenance Records

These specific sections will be discussed following a descri ption of the GeoStar sUAS system and proposed operations under

a Section 333 exemption.ACI_201501 14 _333 

### January 2015 11 

### Review of Section 333 Conditions.

T he Congressional mandate in Section 333 of the Reform Act allows a limited introduction of c ommercial Unmanned Aerial

Systems ( UASs ) into the national airspace system in advance of permanent r ulemaking

, if it can be accomplished safely. T he

Secretary is given the discretion to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a

threat to national security when considering the fo llowing:

- The UAS’s size, weight, speed, and operational capability;

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

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

We shall address these conditions as the y apply to GeoStar sUAS and the proposed operations

.ACI_201501 14 _333 

### January 2015 12 

### SECTION I I

– THE GEOSTAR sUAS DESCRIPTION AND PROPOSED OPERATIONS

GeoStar UAV Dimensions and Weights :

The FAA defin es “Small Unmanned Aerial System s ” (sUAS) a s those that weigh less than 55 pounds. The GeoStar UAV

normally flies at an ope rational weight of 2 1

- 25 pounds, depending on desired battery load. The GeoStar is entirely electric powered

with independent circuits for main propulsion, avionics and telemetry. The GeoStar UAV is constructed with a hollow fiberglass

fuselage. Wings are made from a foam core with carbon fiber reinforcements and then sh eeted with a fiberglass strengthened wood

veneer. The following physical specifications are provided:

a. Wingspan: 157.4” (13’1”)

b. Fuselage length : 72.5”(6’) c. Wing area: 1934 sq. in/13.43 sq. ft. d. Wing cubic loading: 8.1oz per cubic foot (at 25lbs)

e . Empty Weight (No propulsion batteries

, camera payload or parachute ) 14.8 lbs.

f . Maximum gross takeoff weight: 25.0 lbs.

g . Payload Capacity: Up to 1 0

. 2 lbs. of camera

, battery and parachute payload can be carried.

GeoStar UAV 3

- ViewACI_201501 14 _333 

### January 2015 13 

### GeoStar UAV Operating Speeds

The GeoStar UAV was designed as a stable fixed wing aerial photograph y platform with electric power and good payload

capacity

. Slower operational speeds were desired to maximize photographic performance and were achieved th rough substantial wing

area and relatively light wing loading s . Internal mounting of all components minimizes aerodynamic drag and an efficient sailplane

derived airfoil displays excellent handling characteristics across the speed range. All of these cha racteristics combine to facilitate safe

launch

, recovery and efficient cruise performance

. The following speeds are provided based on actual GeoStar flight testing and data

logged by telemetry and onboard airspeed instrumentation . Speeds were measured at the maximum weight of 25lbs :

a

. Maximum speed, level flight: 65mph

b. Stall Speed Clean : 2 4 mph c. Stall Speed Max Flaps: 21mph

d. Cruise/Photo collect speed : 40

- 45mph

e. Power

- off glide speed: 40mph

f . Best rate of climb speed: 40mph

g

. Rate of Climb : 6 00 fpm (750fpm demonstrated at 21 lbs. mission weights)

GeoStar UAV TakeoffACI_201501 14 _333 

### January 2015 14 

### GeoStar sUAS Description and Operational Capabilities

General: The GeoStar sUAS is designed as a semi

- autonomou s precision aerial photography system

. The entire system is

transported to the collection area in a modified trailer. The GeoStar UAV launche s and recover s at or near each desired collection

area. A two or three person crew of UAV Pilot, Tele metry Operator and (optionally) one Observer operat e the GeoStar sUAS. The

GeoStar UAV is launched like a conventional aircraft by manual pilot control, similar to a standard radio controlled airplane. It

requires a takeoff run of about 20

- 50 feet , depending on weight, wind conditions and runway surface

. Once safely airborne, a n

autopilot is enabled and the UAV flies autonomously along a pre

- programmed route of parallel tracks, holding a steady speed and

altitude. W hen flying autonomously via autopilot control, it remains continuously connected to a Gro und Control Station via two

independent command and control links. The system is designed around collections of up to 1 square statute mile. Flying at a cruise

speed of 40mph, one square mile of terrain can be collected in about 20 minutes. A high

- resol ution digital camera is installed to

capture a series of still photographs. The camera is aimed straight down and is commanded to shoot at timed intervals. To comply

with FAR 91.119 as prescribed in COA 2014

- CSA

- 35 , most missions are flown at an altitude of 500

- 600 feet above the ground. Upon

completion of the photo mission, the UAV descends while return ing to the launch point and enters an orbit at the initial recovery

altitude of 350 feet AGL . The UAV can then be recovered manually by the pilot on the wheels or with a parachute recovery system

. The parachute also serves as an important emergency backup system to safely recover the UAV in the event of a system malfunction.

GeoStar UAV Parachute Recover iesACI_201501 14 _333 

### January 2015 15 Command and Control: The GeoStar UAV is designed to function as a semi

- autonomous aircraft with redundant systems for

connectivity and a conti nuous telemetry interface with a Ground Control Station.

a. Primary Radio Control (RC). Primary, m anual pilot control of the UAV is through a conventional Radio Control (RC)

system. From the RC controller, the UAV Pilot can activate all UAV systems and command the autopilot into different operational

modes. The RC system maintains continuous connecti vity with the UAV and immediately overrides any autopilot function. An

external power amplifier and larger antenna extend Primary RC range to approximately 3sm whe n operating at 300

- 600 feet AGL

b. Autopilot Function. The GeoStar UAV autopilot syste m us es 3 axis gyros, GPS/INS navigation, barometric altimeter,

magnetic compass and pitot/static derived airspeed to perform a variety of automated flight tasks from simple stabilization to fully

autonomous flight and pre cision navigation. Autopilot navigation and control enable s the GeoStar UAV to fly the precise ground

tracks and stable al titudes required for precision aerial s urvey. Successful a utopilot function has been demonstrated in winds aloft

conditions exceeding 20 knots. Altitude holding precision is generally +/

- 5 feet and airspeed stability is typically +/

- 3mph in level or

turning flight. The a utopilot incorporates 5 distinct modes of operation :

- Manual Mode. No autopilot input to flight controls. All control remains with the UAV P ilot via the handheld RC controller

and t he UAV is flown like a standard RC airplane. The UAV is normally launched in this mode.

- Stabilize Mode. In this mode, the autopilot maintains “wings level” and seeks to remain in level flight. The UAV P ilot’s control inputs will maneuver the UAV but upon release of the controls, the UAV returns to level, stabilized flight . Power

level is manually set by the Pilot.

- Loiter Mode. When commanded to Loiter Mode , the UAV will establish a left

- hand orbit of preset radius a nd maintain the

altitude established at the moment Loiter was initialized. A designated airspeed is preset for Loiter mode and maintained throughout the Loiter. The GeoStar Loiter radius is preset to 40 meters and airspeed is pr eset to 40 mph.

- Auto Mode. In this mode, the autopilot steers the aircraft along a route of preset waypoints using 3

- axis gyros, GPS/INS navigation, barometric altimeter, magnetic compass and pitot/static derived airspeed

. I t also will seek and/or m aintain a preset altitude and airspeed. While in Auto mode, t he UAV P ilot can intervene and maneuver the aircraft manually at any time and/or increase the power setting for a faster airspeed. However, the UAV Pilot cannot command a power setting below

a preset Auto Mode minimum airspeed s etting.

- Return to Launch

- point (RTL) Mode. In this mode, the autopilot steers the aircraft back to the launch point and then loiters at a preset altitude

, diameter and airspeed . RTL can be preset as the final l eg of a mission or commanded manually any time the aircraft is within RC range by handheld controller function. RTL can also be commanded via Telemetry Control Interface (discussed below ). The Autopilot also incorporates a number of safety features that will automatically command

the aircraft to RTL under certain Lost Link and low

- voltage conditions.

c. Telemetry Module. A separate telemetry module

, independently powered and operating on a discrete frequency spectrum,

interfaces with the autopilot

. Flight data from the autopilot is broadcast via this module at a rate of 10hz, reporting the aircraft’s

current position, flight parameters and systems status in real

- time. The data is viewed and flight performance can then be monitored at

the Ground Control Station computer by a dedicated Telemetry Operator . The Telemetry system also provides audible cues and alerts

of autopilot mode changes, waypoint progress, lost link alarms, low voltage alarms and o ther malfunctions

. The UAV Pilot is also

able to monitor the Telemetry display and audio cues on a secondary monitor mounted on the RC Controller. Telemetry range

exceeds 3 sm when operating at 500 feet AGL

.ACI_201501 14 _333 

### January 2015 16 Ground Control Station Telemetry Display

– 25 November 2014 Mission In Le Sueur County , MN

The telemetry interface can also command the autopilot independent ly from the Primary RC controller. Commands such as Return to

Launch

- point, Loiter, speed and altitude changes and new waypoints can all be sent via this link. T he parachute recovery system can

be activated from this link as well

. This “Telemetry Control Interface” (TCI) functionality is an important safety feature, affording a

reliable secondary method of controlling and recovering the UAV in the event of lost or interrupted primary RC control.

d. Ground Control Station (GCS)

. AeroLogix sUAS G CS is based in a specially modified trailer. The “Operations T railer ”

is equipped with light and AC power. The trailer provides:

- A 110volt

/ 3500

- watt gasoline powered generator for AC power

.

- Telemetry Operator GCS Computer.

- UAV Pilot Auxiliary Telemetry Display

- GCS Telemetry antenna mountings

- VHF Radio s for air traffic communications.

- GMRS Radios for Communication s between UAV Pilot, Observer and Telemetry Operator.

- Weather station.

- Battery chargers.

- Workbench

, tools and spare parts for assembly and field repairs.

- Transport for all GeoStar sUAS components.ACI_201501 14 _333 

### January 2015 17 Ground Control Station

- Op erations TrailerACI_201501 14 _333 

### January 2015 18 GeoStar UAV Power Scheme. The GeoStar UAV is an all

- electric design, utilizing rechargeable Lithium

- Polymer batteries for all

systems

. Unlike many all

- electric sUAS that utilize a single battery power source, the GeoStar UAV power scheme isolates the

critical system s into independent ly powered and regulated circuits

.

a. Main P ropuls ion Power. The GeoStar UAV can utilize up to four separate “6S” (22.2 VDC) 6000 mAh Lithium

- Polymer

battery cells for main propulsion. C ells are connected in parallel to achieve 12,000, 18,000 or 24,000 mAh of capacity

. The multiple

battery scheme allows tailoring of capacity to fit the mission profile

. The main battery voltage level and current draw is relayed back

to the GCS via telemetry, allowing continuous monitoring of mai n propulsion motor performance and battery state. GeoStar f light

testing revealed remarkable efficiency and endurance. With a full battery load of 24,000mAh, endurance at no rmal cruise speeds can

exceed 60 minutes while a fford ing a 15 minute reserve capacity. Specific battery consumption and mission profiles will be discussed

later in this document.

b. Avionics Power. The Avionics system in the GeoStar UAV is comprised of the Primary RC Receiver, a utopilot system,

voltage regulators and system servos. Avionics power is provided by two Lithium

- Polymer “2S”, 7.4 VDC rechargeable batter ies

connected in parallel

. The avionics battery voltage level and current draw is relayed back to the GCS via telemetry, allowing

continuous monitoring of b attery state. The useful du ration of th ese batteries exceeds 3 hours, insuring positive control and autopilot

function well beyond the endurance of the Main Propulsion Batteries. An autopilot Power Module regulates and conditions power for

the Autopilot and RC Receiver. The servos are powered from a separate power converter and isolated servo power circuit within the

Autopilot

. A total of 11 servos are utilized by the GeoStar UAV. Servos are the only likely source of electrical noise or voltage

fluctu ations within the avionics power circuits. By isolating the servos to their own regulated power circuit, any anomalies within the

servo circuit will not affect the sensitive autopilot and RC Receiver functions. The avionics battery performance is depicte d below

based on telemetry data from a 25

- minute mission :

Avionics Battery Performance 7.95

7.83 7.89 7.87 7.87 7.87 7.86 7.85 7.85 7.82 7.8

50% 60% 70% 80% 90% 100%

7.40 7.50 7.60 7.70 7.80 7.90 8.00

00:00 03:00 06:00 09:00 12:00 15:00 18:00 21:00 24:00 27:00 Capacity Remaining Avionics Battery Voltage

Elapsed Time 

## Avionics Battery Performance

- 4400 mAh Capacity

Avionics Voltage Capacity RemainingACI_201501 14 _333 

### January 2015 19 c. Telemetry Power. The aircraft’s telemetry module is powered independently by its own 7.4 VDC Lithium

- Polymer

battery and power regulator that provide a steady 5.5 VDC. The t elemetry module battery duration exceeds 2 hours at max power

output. The telemetry battery performance is depicted below based on measurements before and after a 25

- minute mission:

Telemetry Battery Endurance 8.01 7.98 7.97 7.96 7.95 7.94 7.93 7.92 7.91 7.91 7.89

0% 20% 40% 60% 80% 100%

7.40 7.50 7.60 7.70 7.80 7.90 8.00 8.10

00:00 03:00 06:00 09:00 12:00 15:00 18:00 21:00 24:00 27:00
Elapsed Time 

## Telemetry Battery Performance

- 2200 mAh Capacity

Telemetry Voltage Capacity RemainingACI_201501 14 _333 

### January 2015 20 Flight Profile and Endurance. Operating within the constraints of COA 2014

- CSA

- 35

– namely operations within visual range

-

GeoStar operations in the Fall of 2014 were generally within 1sm of the launch point . T he complete load of 4 main propulsion

batteries was not always required to comply with our COA mandated 3 0 minute reserve requirement of 14 CFR 91.151, (Minimum

Fuel Requirements) . Sufficient endurance for shorter test and photo missions w as afforded with two or three main propulsion

batteries

. Power consumption rates were recorded on all flights and those figures a llow accurate estimation of battery consumption.

For reasons to be discussed later in this application

, AeroLogix will be requesting an exemption from the requirements of 14

CFR 91.151. The maximum anticipated flight profile for most missions will be approximately 30 minutes from start to finish

.

E nvisioned operations will keep the UAV within 1

- 2 sm of the GCS

. The following table and graph depict a typical photo mission

collecting 1sq mile and reveal a generous 32 % reserve capacity when operating with just two main propulsion batteries. This

represents an available 15 minutes of reserve capacity at cruise power settings. Consumption rates were compiled from actual

GeoStar telemetry feeds whe n operating at temperatures of 25 O

- 50 O F. The “Amp Draw” value during the “Collect” phase is an

average value as the rate varied from 10

- 20amps at different times during the collection s

.

GeoStar Mission Profile

– Battery ConsumptionACI_201501 14 _333 

### January 2015 21 GeoStar sUAS Systems Redundancy

. In order to achieve maximum safety of operations, a nother specific design goal of the

GeoStar sUAS was systems redundancy to avoid “single point of failure” scenarios

. The following design features of the GeoStar

sUAS were incorporated to maximize reliability and safety of operations:

a. Aileron Control Servo Redundancy. The GeoStar UAV employs dual ailerons on each wing panel, each actuated by its

own independent servo. In the unlikely event of an aileron servo or linkage malfunctio n, partial yet positive aileron control remains

on the affected wing panel.

b. Elevator Control Servo Redundancy. In a similar fashion to the ailerons, each elevator surface is actuated by its own

independent servo. If a single elevator servo or linkage malfunction occurs
, sufficie nt elevator authority is maintained on the other to

safely maneuver and recover the UAV

.

c. Main Propulsion Battery Redundancy. The GeoStar UAV employs from 2 to 4 main propulsion battery cells connected in

parallel. While unlikely, an internal battery or connection failure of one cell will not result in a complete loss of main propulsion

power. In the most likely flight profile scenarios, t he remaining cell(s) w ill provide sufficient power for a return to the launch point

and safe recover y of the UAV. A battery failure will be indicated at t he GCS by telemetry data indicating a more rapidly decreasing

battery voltage.

d. Avionics Battery Redundancy. In a similar fashion to the main p ropulsion b atteries, two avionics batteries are connected

in parallel to power the critical Autopilot and s ervo circuits. While unlikely, an internal battery or connection failure of one cell will

not result in an immediate loss of avionics power. In the most likely flight profile scenarios, the remaining cell will provide sufficient

avionics power for a return to the launch point and safe recover y of the UAV.

e. GCS Systems Redundancy. The GeoStar sUAS Ground Control Station (GCS) has a portable electric generator with an

endurance exceeding 12 hours. The critical flight control and communication systems are battery powered with rechargeable

batteries. The generator insures these s ystems remain on AC power a nd in a fully charged state as the GeoStar sUAS is operated. In

the event of a generator shutdown, all components revert to their battery power, allowing successful return and recovery of t he

GeoStar.ACI_201501 14 _333 

### January 2015 22 GeoStar sUAS Lost Link/Failsafe Descriptions

- General . As described earlier in this application, t he GeoStar UAV employs two,

separate Command and Control Links operating on discrete frequencies. Either link system can command the UAV to Return To

Launch

- point (RTL) and/or command Parachute Deployme nt. The complete loss of either link system will command an immediate

and automatic Return To Launch

- Point (RTL) mod e change within the a utopilot

. The UAV will autonomously return and then orbit

over the launch point at a safe, predetermined altitude an d airspeed . All lost

- link conditions are tested and confirmed during GeoStar

UAV preflight actions.

GeoStar sUAS Lost Link/ Failsafe Description s

– Primary RC Control Link

. The UAV Pilot manually controls the GeoStar UAV

and commands Autopilot modes via the Primary RC Link. The RC Controller remains powered, connected and in the possession of

the UAV Pilot throughout the GeoStar mission profile

. If the Primary RC control link is lost at any time, a sequence of events is

automatically triggered:

a. S hort T erm I nterruption Failsafe

– Primary RC . When an interruption of the Primary RC link exceeds 1.5 seconds , the

Autopilot commands a “Circle” mode, whereby the UAV begins a circular flight path and holds a steady altitude. Circle r adius is

preset to 40 meters. The Telemetry Computer will report visually “FAILSAFE” and audibly announce , “MODE CHANGE TO

CIRCLE” followed by, “NO DATA FOR 10 SECONDS”, “NO DATA FOR 15 SECONDS” etc.. If the Primary RC link is

reestablished within 20 se conds, the Autopilot remains in “Circle” mode until the UAV Pilot commands a new Autopilot mode.

b. L ong T erm I nterruption Failsafe

- Primary RC

. When an interruption of the Primary RC link exceeds 20 seconds , the

Autopilot will automatically command a Return to Launch

- Point ” (RTL) mode change. The Telemetry Computer will report visually

“FAILSAFE” and audibly, “NO DATA FOR 20 SECONDS”, “MODE CHANGE TO RTL,” whereby the UAV immediately begins a

return to the launch point and a descent to the recovery altitude. If the Primary RC link is reestablished after the automatic RTL is

initiated, the Autopilot remains in RTL mode until a new Autopilot mode is commanded by the UAV Pilot.

Telemetry Computer Display

- Primary RC Link Fail

- Safe IndicationACI_201501 14 _333 

### January 2015 23 GeoStar sUAS Lost Link/Failsafe Descriptions

– Telemetry Link

. The Telemetry link is continuously monitored during a GeoStar

sUAS mission by a dedicated Telemetry Operator. Link status and signal strength is reported in the main Telemetry Display. The

“%” value represents the percentage of good data packets received via the Telemetry link. The signal strength is indicated b y 1

- 3

vertical bars.

Telemetry Connection Status

a. L ost Telemetry Link Indications. Momentary losses of Telemetry Link are se en on the Telemetry display as loss of signal

strength and/or a decrease in the percentage value of data packets. When a continuous loss exceeds 5 seconds , the program announces

“NO DATA FOR 5 SECONDS,” “NO DATA FOR 10 SECONDS” etc... A complete loss of telemetry data is indicated by a

“Failsafe” indication and a red “ X “ in the telemetry status area of the Telemetry Display.

Lost Telemetry DisplayACI_201501 14 _333 

### January 2015 24 b. Lost Telemetry Link Failsafe . The GeoStar UAV Autopilot is programmed to trigger an automatic Fai lsafe RTL if

Telemetry loss exceeds 20 continuous seconds. The Autopilot will command RTL, whereby the UAV immediately begins a return to

the launch point and a descent to the recovery altitude. The Telemetry Computer will announce, ““NO DATA FOR 20 SECO NDS.”

It will continue to make “NO DATA” announcements at 10 second intervals until the Data Link is restored or until silenced by the

Telemetry Operator. The Telemetry Computer will continue to visually report “FAILSAFE.” With a complete loss of Teleme try data,

the mode change to RTL can only be evidenced visually by the UAV Pilot and/or the Observer. If the Telemetry Link is reestablished

after the automatic RTL is initiated, the Autopilot remains in RTL mode until a new Autopilot mode is commanded by the UAV Pilot.ACI_201501 14 _333 

### January 2015 25 GeoStar sUAS Lost Link/Failsafe Descriptions

– Simultaneous Primary RC and Telemetry Links Lost. To mitigate the risk of

this scenario, Command and Control links to the GeoStar UAV are independently powered, both in the UAV itself and at the GCS

. The independent batteries powering the UAV Telemetry and Avionics have a useful duration that greatly exceeds the battery lif e of

the Main Propulsion System. While unlikely, the possibility exists for both Command and Cont rol links to malfunction. Two

possible scenarios exist in this case. Outcomes and actions depend on the functionality of the UAV a utopilot . If the GeoStar retains a

functioning a utopilot , RTL will be commanded upon loss of either link and the aircraft w ill return and orbit over the launch point at a

predetermined altitude.

a. Simultaneous Primary RC and Telemetry Links Lost

– Autopilot Functional. A functional Autopilot affords options in

dealing with a complete Command and Control Link loss. As discussed earlier, a loss of either link wil l trigger an automatic RTL and

l oiter over the launch point at a safe, pre

- determined altitude. This affords time to troubl eshoot each system and ideally perform an

immediate Parachute Recovery. If contact c annot be regained, the UAV will orbit at the launch site until Main Propulsion batteries

are exhausted. As the main propulsion battery voltage diminishes, a slow circling descent at approximately 40mph will occur at the

launch point until ground impact. Since the autopilot /avionics circuit is independently powered, t he autopilot will continue to

command a 40 meter orbit radius throughout this descent.

b. Simultaneous Primary RC and Telemetry Links Lost

– No Autopilot Functional. While extremely unlik ely, t his scenario

represents the “worst case” scena rio to an airborne GeoStar UAV. All Failsafe parameters are stored in the Autopilot and a

malfunction of this system could disable Failsafe logic and control performance. A complete loss of Primary RC and Telemetry links

as well as autopilot functions and failsafe modes will likely result in uncontrolled/uncommanded flight. UAV actions d epend on the

nature of the autopilot malfunctions and the resulting inputs to the flight control servos. I f the UAV fails to RTL , fails to respond to

control inputs or mode ch ange s from either Command and Control link, the UAV Pilot and crew have few options. If the UAV

remains in stable flight despite complete loss of both links and Autopilot , troubleshooting at the GCS shall be attempted to regain

Command and Control. The long connectivity ranges afforded by both the Primary RC a nd Telem etry Link help in this regard. If the

UAV continues to fly away in stable flight, it could potentially do so until the Main Propulsion batteries are exhausted. In a clean

configuration and neutral flight control surfaces, a n unpowered gliding descent at approximately 40mph and 100

- 500 fpm will occur

until ground impact.

GeoStar sUAS Lost Link/Failsafe Descriptions

– Low Vol tage Failsafe s

. The GeoStar UAV autopilot system is capable of

monitoring the voltage and current levels of the avionics circuit. With the avionics circuit batteries having over a much longer

duration than main propulsion batteries, the likelihood of an avionics low

- voltage scenario is remote . The failsafe remains a useful

tool in the event of a battery malfunction. Low voltage conditions in this circuit will trigger one of two automated failsafe respon ses

to maintain UAV functionality and effect a saf e recovery.

a) 1 st Low Voltage Threshold. When avionic s voltage drops below 7.0 volts , an audible alarm announces

“ WARNING

- LOW VOLTAGE”

b) 2 nd Low Voltage Threshold. When avionics voltage drops below 6. 8 volts, automatic RTL is initiated.ACI_201501 14 _333 

### January 2015 26 

### GeoStar sUAS General Operating Parameters

Proximity to Airports: Operating under the provisions of COA 2014

- CSA

- 35, AeroLogix i s not allowed to operate the GeoStar

sUAS within 2nm of the public airports in or near Le Sueur County. We are allowed to ope rate within the Class E surface area near

the uncontrolled Ma nkato airport (KMKT) provided we remain outside of 2nm and monitor the CTAF frequency . We are required to

terminate the flight/ exit the K MKT Class E Surface Area when aircraft broadcast intentions to depart or land on certain runways.

Th ese limitations have not significantly impacted operations. AeroLogix requests the same authorization s for uncontrolled airport

proximity as previously granted in COA 2014

- CSA

- 35.

With potential comm ercial operations in many different areas, AeroLogix recognizes the need for greater planning and

coordination when operations are desired near or within controlled airports and airspace . AeroLogix anticipates additional

requirements/limitations in this r egard with a 333 exemption. We request consideration and authorization of GeoStar sUAS

operations in Class D and C airspace provided prior coordination and approval with appropriate ATC is conducted and postive

communications can be as sured.

Operations within Mode C Veils: Operating under the provisions of COA 2014

- CSA

- 35, AeroLogix is authorized to operate the

GeoStar sUAS in a portion of the MSP Mode C veil without a transponder, provided operations remain in Class G airspace and pr ior

coordination wi th Minneapolis Approach ATC is performed. The dual command and control systems were deemed appropriate

mitigation for the requirements of 14 CFR 9 1.215 . As COA 2014

- CSA

- 35 states:

“ The GeoStar separate Command and Control links and ATC approval are acc eptable mitigations for 14 CFR 91.215 requirements in the absence of a Mode C transponder. ”

AeroLogix requests the same a uthorizations for operations within Mode C veils as previously granted in COA 2014

- CSA

- 35.

Proximity to Densely Populated Areas: Operating under the provisions of COA 2014

- CSA

- 35, AeroLogix i s not allowed to operate

the GeoStar sUAS over densely populated areas. These are generally depicted on FAA Sectional and Terminal Area Charts in yellow.

AeroLogix is not seeking authorization to operate over densely populated areas and only requests the same authorization s previously

granted in COA 2014

- CSA

- 35.

Weather Minimums: Operating under the provisions of COA 2014

- CSA

- 35, AeroLogix operates the GeoStar UAV in day VMC

conditions with at least 3sm of visibility and a ceiling no lower than 1000’AGL. The following conditions were prescribed.

Unless otherwise authorized as a special provision, all operations must be conducted in visual m eteorological conditions (VMC) during daylight hours in compliance with Title 14 of the Code of Federal Regulations (CFR) Part 91 §91.155 and the following:

... Special Visual Flight Rules (VFR) operations are not authorized.

... VFR cloud clearances specified in 14 CFR Part 91 §91.155, must be maintained, except in Class G airspace where Class E airspace visibility requirements must be applied, but not less than 3 statute miles (SM) flight visibility and 1000’ ceiling.

...Night op erations are prohibited unless otherwise authorized as a special provision.

AeroLogix requests the same authorizations for operational weather minimums as previously granted in COA 2014

- CSA

- 35.ACI_201501 14 _333 

### January 2015 27 Operations within V isual Line Of Sight : Operating under the provisions of COA 2014

- CSA

- 35, GeoStar sUAS operations must

remain in visual contact with the UAV Pilot or up to one qualified observer. The Observer must remain in constant radio cont act with

the UAV Pilot and Telemetry Operator whene ver the GeoStar flies beyond the visual range of the UAV Pilot. No “daisy

- chains” of

observers are allowed. AeroLogix does not seek operations with multiple observer “daisy chains” or any operations beyond visual

range. AeroLogix only requests the same authorization s as previously granted in COA 2014

- CSA

- 35.

Compared to many sUASs, the GeoStar is a much larger aircraft (13’ wingspan) and has a distinctive shape and coloring to

facilitate visual contact. Flight testing the GeoStar UAV at altitudes of 300

- 550 feet AGL revealed visual contact can be maintained

to approximately 1sm with the unaided eye.

GeoStar UAV in FlightACI_201501 14 _333 

### January 2015 28 

### GeoStar sUAS

– Operational Scenarios

Ope rational Scenarios

– General: Operating under the provisions of COA 2014

- CSA

- 35, GeoStar sUAS operations are limited to a

maximum altitude of 600 feet AGL while also being required to comply with 14 CFR 91.119 ( Minimum Safe Altitudes )

– requiring a

500 foot clearance from objects or persons on the ground. As a result, the current GeoStar imaging system is optimized for collections

in the 500

- 600 foot AGL range. Flight operations in 2014 revealed this to be a practical altitude block for the GeoStar sUAS.

AeroLogix does not seek exemption from 14 CFR 91.119 or operational altitudes higher than 600 feet. We only request the same

altitude authorizations previously granted in COA 2014

- CSA

- 35. AeroLogix anticipates three types of collec tion scenarios with the

GeoStar sUAS.

- Area Survey

- Road/Utility Survey

- Irregular Route Survey



### Operational Scenario

– Area Survey: Area surveys are usually flown with a series of parallel tracks. Track spacing is

determined by desired imagery parameters . Operating between 500 and 600 feet AGL with the standard imaging configuration , t he

GeoStar sUAS can map an area of one square mile in approximately 20

- 25 minutes. While the GeoStar UAV is capable of flying and

collecting much larger areas, a dditional operational and technical factors come into play that make larger areas less practical.

AeroLogix intends to scale each area collection flight to one square mile or less . When conditions dictate a flight path beyond visual

range of the UAV Pilo t, AeroLogix will post a qualified observer

. A standard 1sq mile area collection is depicted below:

1sq Mile Area Survey Plan DepictionACI_201501 14 _333 

### January 2015 29 Operational Scenario

– Road/Utility Survey: Road and utility surveys are another highly anticipated mission for the GeoStar

sUAS. The GeoStar sUAS can create s urvey grade imagery and engineering products on short notice and at a significant cost savings

to public and private organizations. AeroLog ix intends to collect these surveys in segments of up to 2sm, generally flying 3 parallel

tracks . Limiting the segments to 2sm or less insures the UAV remains within visual range of the UAV Pilot and up to one observer. It

also affords a generous excess of connectivity ranges. Flying 3 parallel tracks, a linear 2

- mile segment can be collected in

approximately 12

- 15 minutes. A typical 2sm r oad s urvey is depicted below:

2 Statute Mile Road Survey DepictionACI_201501 14 _333 

### January 2015 30 Operational Scenario

– Irregular Route Survey: Many anticipated collections will involve irregular flight paths in order to

accurately survey non

- linear agricultural ditch e s, rivers, streams and roads. Most collections will in volve closely spaced paralle l

track s along the path, collecting overlapping photos on both tracks. AeroLogix intends for the GeoStar to remain within 2sm of the

launch point, to insure the UAV remains within visual range of the UAV Pilot and up to one observer. It also affords a ge nerous

excess of connectivity ranges. Depending on route geometry, most collections will be completed in 15

- 20 minutes. The route depicted

below can be collected in approximately 15 minutes, including time for launch, climb and recovery.

Irregular Route Survey

– Agricultural DitchACI_201501 14 _333 

### January 2015 31 

### SECTION I I I

- SPECIFIC CFR EXEMPTION REQUESTS & SUPPORTING EXPLANATIONS

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Certifications Required

14 CFR Part 21, Subpart H, establishes the requirements for the issuanc e of airworthiness certificates;

14 CFR 91.203(a)(1) establishes the require ment for all civil aircraft to have a C ertificate of A irworthiness

Explanation Supporting Exemption The FAA publication, “ Public Guidance for Petitions for Exemption Filed under Section 333 ” Rev. 9/25/2014, states:

Section 333 of the Reform Act grants the Secretary of Transportation authority to determine:

1. If an unmanned aircraft system, as a result of its size, weight, speed, operational capabi lity, proximity to airports and populated areas, and operation within visual line of sight does not create a hazard to users of the national airspace system or the public or pose a threat to national security; and

2. Whether a certificate of waiver, certificate of authorization, or airworthiness certification under 49 USC § 44704, is required for the operation of unmanned aircraft systems identified under paragraph (1).

AeroLogix respectfully submits that airworthiness certification under Part 21 is not required for safe operation of

the GeoStar sUAS in the NAS

. Operating under the provisions of COA 2014

- CSA

- 35, GeoStar sUAS flight operations

were authorized by the FAA without an Airworthiness Certificate

. Le Sueur County was allo wed to certify GeoStar

UAV airworthiness as a public aircraft and to dispatch AeroLogix and the GeoStar sUAS on aerial survey missions

throughout most of the county. AeroLogix and Le Sueur County worked jointly to develop and document the procedures

for s afe operation and continued airworthiness of the GeoStar sUAS. This documentation is provided with our

application. With successful flight operations and smooth integration into the NAS in 2014, AeroLogix has successfully

demonstrated its competence in d esigning, constructing , maintaining an d operating the Ge oStar sUAS in the NAS

.

The GeoStar UAV has proven to be an airworthy, safe and reliable sUAS aircraft. The size, weight and speed

parameters were described earlier in detail along with a full description of i nnovative design features that enhance safety

. While meeting the FAA criteria for sUAS systems, the GeoStar sUAS design surpasses many current sUAS systems in

safety and redundancy features

.

From an operational perspective

, AeroLog ix intends to opera te the identical GeoStar sUAS system under similar

operational and airspace conditions as previously vetted and approved by the FAA in COA 2014

- CSA

- 35. Aer oLogix

intends short duration flights in rural, sparsely populated areas, within visual range and in compliance with 14 CFR

91.119 . All GeoStar operations will be conducted by a certificated Private Pilot or FAA prescribed alternative

qualification.ACI_201501 14 _333 

### January 2015 32 

### Collectively, w e believe these factors combine to fulfill the conditions expresse d in Section 333 and merit worthy

consideration for exemption as expressed in the Reform Act

. We assert that by design

, operational intent and by

successful NAS integration already demonstrated in 2014

, that the GeoStar sUAS will achieve equivalent or gre ater levels

of safety as those demonstrated by conventional providers of Aerial Survey.ACI_201501 14 _333 

### January 2015 33 

### 14 CFR § 45.23 Display of marks; general. 14 CFR § 45.25 Location of marks on fixed

- wing aircraft.

14 CFR § 45.29 Size of marks.

14 CFR 45.23 ( a ,b) Establishes required markings for aircraft and additional markings requirements fo r

L imited, R estricted

, L ight Sport, E

xperimental or provisionally certificated aircraft

14 CFR 45.25 (a,b ) Establishes locations for prescribed markings

14 CFR 45.29(a,b ( 1 ) ) Establishes marking size criteria for fixed wing aircraft

Explanation Supporting Exemption

The first GeoStar sUAS airframe was required to be register ed with the FAA and a n application was submitted in

December 2014 . Approval and assignment of a registration “N” number is pending approval as of this writing.

AeroLogix will be registering all subsequent GeoStar airframes as they are completed

.

Due to the ai rcraft size, it is not possible to comply with the size and location requirements expressed above. A

request for an alternate form of compliance was filed with AFS

- 86, UAS Airworthiness Section and has been approved.

The approved alternative involve s 4

- inch letters affixed to upper and lower wing surfaces and 1

- inch letters on either side

of the vertical stabilizer

/rudder . AeroLogix respectfully requests that subsequent GeoStar UAV airframes be authorized

marking in accordance with the approved alternative marking scheme for the first GeoStar airframe.

P roposed “N” Number Marking Locations

– (Pending Approval with FAA)ACI_201501 14 _333 

### January 2015 34 

### 14 CFR § 61.113 Private Pilot Privileges and Limitations : Pilot In Command 14 CFR § 61.133 Commercial Pilot Privileges and Limitations.

14 CFR 61.113 (a,b) L imits P rivate P ilots to non

- commercial operations

14 CFR 61.133 (a) E stablishes P ilot in C ommand certification requirements of an aircraft used for compensation or hire.

Explanation Supporting Exemption

AeroLogix respectfully seeks exemption to allow the Pilot i n Command of the GeoStar sUAS to conduct

commercial sUAS operations with a Private Pilot Certificate or FAA authorized alternative. GeoStar sUAS flight

operations under COA 2014

- CSA

- 35 prescribed a minimum acceptable Pilot in Command (PIC) as:

... The PIC must hold, at a minimum, a current FAA private pilot certificate or the FAA accepted agency equivalent, based on the application or 14 CFR Part 61.under all operations: (1) Approved for flight in Class A, B, C, D, E, and G (more than 400 feet abo ve ground level (AGL)) airspace

... Operations without a pilot certificate may be allowed when all of th e following conditions are met: (1) The PIC has successfully completed, at a minimum, FAA private pilot ground instruction and passed the

written exa mination, or the FAA accepted agency equiva lent, based on the application.

AeroLogix intends to opera te the identical GeoStar sUAS system under similar operational and airspace

conditions as previously vetted and approved by the FAA in COA 2014

- CSA

- 35. We respectfully request the same

authorizations with re gards to Pilot qualifications. A eroLogix recognizes that UAS operational safety is greatly enhanced

by the knowledge and experience that come with a Pilot certificate and recent flying experience of conventional aircraft in

the NAS.ACI_201501 14 _333 

### January 2015 35 

### 14 CFR § 91

. 7 (a) Civil Aircraft Airworthiness

14 CFR 91.7 (a) States that no person may operate a C ivil Aircraft unless it is in an airworthy

condition.

Explanation s Supporting Exemption

AeroLogix respectfully seeks exemption from 14 CFR 91. 7 (a) due to civil aircraft “airworthiness” generally

being defined by the conditions that support the granting of an Airworthiness Certificate in compliance with 14 CFR Part

21. AeroLogix is seeking e xemption from the requirements of 14 CFR Part 21 and thus cannot comply with the definition

of airworthiness as defined by that P art

.

AeroLogix intends full compliance with 14 CFR 91.7 (b) that prescribes a more general definition with the Pilot

in Command as being responsible for determining:

...whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.

The Pilot in Command assembles the GeoStar UAV at the launch site and performs all preflight assembly and inspection

in accordance with the procedures set forth in GeoStar sUAS Operations Manual. This manual is submitted for FAA

reference with this application.



### 14 CFR § 91.9 (b)(2) Civil Aircraft Flight Manual in the Aircraft

14 CFR 91. 9 (b)(2) (regarding flight manuals)...“ is available in the aircraft a current

approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. ”

Explanation Supporting Exemption

AeroLogix respectfully seeks exemption from 14 CFR 91.9 ( b ) (2) due to the size and nature of the sUAS and

Pilot access to such manuals. AeroLogix submits an equivalent level of s afety will be achieved by keeping the GeoStar

UAV Operations Manual at the Ground Control Station.ACI_201501 14 _333 

### January 2015 36 

### 14 CFR § 91. 1 09(a) Flight Instruction

14 CFR 91. 1 09 (a) Requires flight instruction be conducted in aircraft with fully functioning dual controls.

Explanation Supporting Exemption

AeroLogix respectfully submits that the GeoStar sUAS is not capable of compliance with this regulation due to

the unmanned, remotely piloted nature of its design. Any flight instruction performed with a prospective UAV P ilot shall

be conducted with a secondary RC Controller (“buddy box”) wired to the Primary RC Controller. The “buddy box”

allows the Instructor Pilot to transfer control to the Trainee Pilot’s RC controller via a positive push

- button switc h. If the

Instructor Pilot is required to resume control, he simply releases the switch and control is instantly transferred back to the

Primary RC Controller and the Instructor Pilot. AeroLogix submits that an equivalent level of safety is achieved with this

arrangement as are dual controls in a conventional aircraft.



### 14 CFR § 91. 121 Altimeter Settings

14 CFR 91. 121(a) Establishes requirements for barometric altimeter settings when operating below 18,000

feet MSL

Explanation Supporting Exemption

AeroLogix respectfully seeks exemption from 14 CFR 91.121 ( a ) . The GeoStar UAV autopilot system has an

internal barometric sensing altimeter that does not incorporate a means to manually adjust for pressure variation . Each

time the autopilot initialize s, the altimeter automatically calibrate s and establishes the initialization altitude as zero (0) feet

AGL. All altitudes referenced and used by the autopilot are in AGL values. GPS altitudes are available as a secondary

altitude reference in the event of a barometric altimeter failure. Failsafe logic automatically reverts to GPS altitudes in the

event of a barometric altimeter failure. AeroLogix submits that an equivalent level of safety will be achieved by the

automated altimeter calibratio n and GPS failsafe logic

.ACI_201501 14 _333 

### January 2015 37 

### 14 CFR § 91. 151 (a)(1 ) Fuel Requirements for Flight in VFR Conditions.

1 4 CFR 91.151(a) (1,2) (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;

Explanation s Supporting Exemption

While the GeoStar UAV is capable of complying with this regulation for many projected mission profiles

,

Aero Logix respectfully requests exemption from the requirements of 91.151 for GeoStar sUAS

. Compliance with this

regulation requires loading of additional batteries and increases the w eight of the GeoStar UAV. While performance is

satisfactory at the maximum weight of 25 lbs., a shorter reserve requirement would allow fewer batteries and l ighter

weights for shorter mission profiles . This would allow greater efficiency, shorter takeoff and landing r un s
, less stressful

parachute recoveri es and better management of battery packs in the field. Operating with the 12,000 mAh “twin pack,”

most projected mission profiles can be launched, flown and recovered while maintaining a 15 minute reser ve capacity.

GeoStar flight operations in 2014 demonstrate d that 15 minutes would be an adequate reserve capacity based on the

following criteria:

1) Proximity to launch and recovery location. The GeoStar UAV launches and recovers from the same location

.

M aximum ranges shall not exceed approximately 2sm for most projected operations

. At cruising speed, the GeoStar

requires only 2

- 3 minutes of flight time to return to the launch/recovery location.

2) Short Duration Flights. 91.151 contemplates a pilot/passenger

- carrying flight to a destination airfield in VFR

conditions

. The prescribed reserve affords a limited measure of dealing with slower

- than

- projected groundspeeds en route

or delays ge tting into the arrival airport. These issues are generally not a consideration for the GeoStar sUAS as it

operates for relatively short periods of time and within a very short distance of the launch/recovery point.

3) Excess Reserve Capacity Aggravates “Lost Link/Flyaway” Scenarios. While extremely unlikely to occur, the

possibility exists for a malfunction to caus e uncommanded flight for the duration of the main propulsion batteries. 30+

minutes of reserve capacity could compound the issues faced in this scenario by potentially causing the UAV to fly away

farther and higher. 15 minutes of reserve capacity is sufficient to perform all GeoStar sUAS lost

- link troubleshooting

procedures and would limit the maximum range attainable in a f lyaway scenario

.ACI_201501 14 _333 

### January 2015 38 

### 4) Independent Power Circuits for Avionics , Telemetry and Main Propulsion. The GeoStar sUAS telemetry and

avionics circuits a

re not dependent on the main propulsion batteries for their endurance and reserve capacity . These

batteries will continue to control gliding flight and/or command parachute deployment for 2

- 2 .5 hours beyond the main

propul sion bat teries’ maximum endurance.

5) Telemetry data for real

- time status of the main propulsion batteries. The main propulsion battery voltage level

and current flow is fed to the GCS via telemetry link. The UAV Pilot is able to monitor this data in real time and assess

battery conditio n and motor performance as a mission progresses.

6 ) Projected Flight Profiles and Battery Loads

. A 15 minute reserve allows much better loading flexibility for the

GeoStar sUAS. While most anticipated missions will be flown in less than 30 minutes, the GeoStar imaging system can

be fitted with a variety of lenses that deliver imaging “footprints” of different sizes. Capturing very high

- resolution

images with smaller footprints ca n require longer flight times to capture an equivalent area. Flight profiles for the

different battery configurations are depicted in the tables and graphs below

. The “Amp Draw” value during the “Collect”

phase is an average value. T he actual rate varie s as the battery voltage diminishes over time and as the autopilot manage s

the power level during the collection s

. Rates are based on actual GeoStar telemetry feeds when operating at temperatures

of 25 0



### - 50 0 

### F.ACI_201501 14 _333 

### January 2015 39 

### a) 12,000mAh Twin Pack Battery Endur ance Profile. Allowing for a 15 minute reserve, this battery load

allows a collection of up to 25 minutes and overal l flight profile of just over 31 minutes. The majority of likely operations will fall within this flight profile.ACI_201501 14 _333 

### January 2015 40 

### b ) 18,000mAh Triple Pack Battery Endurance Profile. Allowing for a 15 minute reserve, this battery

load allows collections of up to 3 8 minutes and an overall flight profile of approximately 45 minutes.ACI_201501 14 _333 

### January 2015 41 

### c) 24,000mAh Quad Pack Battery Endurance Profile. Allowing for a 15 minute reserve, this battery load

allows collections of up to 5 0 minutes and overall flight profile of approximately 56 minutes.

6) Summary. Since the first GeoStar test flight, the compiling of battery consumption and performance data has

been a primary objective. AeroLogix can now accurately predict the endurance for the various battery configurations and

monitor performance in real time against this data. AeroLogix respectfully submits tha t when consideration is given to

the GeoStar sUAS operational parameters, systems redundancy , telemetry data feeds and the improved flight performance

gained by flexible loading options, an equivalent level of safety can be achieved with 15 minutes of rese rve capacity for

main propulsion batteries.ACI_201501 14 _333 

### January 2015 42 

### 14 CFR § 91. 207 (a)(1) Emergency Locator Transmitters (ELTs)

.

14 CFR 91. 207 (a)(1) Establishes the requirement that all US

- Registered Civil Aircraft must attach an

approved, automatic ELT.

Explanations Supporting Exemption

AeroLogix respectfully seeks exemption from 14 CFR 91.207 ( a ) (1). The size and weights of available ELT

systems preclude their installation into the GeoStar UAV. AeroLogix submits that an equivalent level of safety to an ELT

system is achieved with the real

- time telemetry feed of the UAV’s position and operations within visual range.



### 14 CFR § 91. 307 (a) Parachutes and Parachuting

14 CFR 91. 307 (a ) Establishes: No pilot of a civil aircraft may allow a parachute that is available for

emergency use to be carried in that aircraft unless it is an approved type and has been packed by a certificated and appropriately rated parachute rigger

—
.

Explanations S upporting Exemption

T he AeroLogix GeoStar UAV utilizes a 12’ or 14’ parachute for use in both normal and emergency recoveries.

The parachute is of a very lightweight design and synthetic material originally used in amateur rocketry. “Approved

Type” pa rachutes for use by human parachutists are not of a practical size or weight to be compatible with the GeoStar

UAV. AeroLogix submits that this regulation is not applicable to the GeoStar sUAS and respectfully seeks exemption.ACI_201501 14 _333 

### January 2015 43 

### 14 CFR Subpart E Maintenance, Preventative Maintenance and Alterations

14 CFR § 91.405 (a) Maintenance Required 14 CFR § 9 1.407 (a) (1) Operation After Maintenance, Preventative, Rebuilding or Alteration

14 CFR § 91.409 (a) (1)(2) Inspections

14 CFR § 91.417 (a)(b) Maintenance Records

14 CFR Subpart E Establishes maintenance requirements for US

- Registered Civil Aircraft.

Explanations Supporting Exemption

The regulations cited above prescribe maintenance requirements and recordkeeping for aircraft maintained in

accordance with Part 43. Aircraft of this type are those that have an Airworthiness Certificate and have met the

requirements for c ertifi cation und er 14 CFR 21 Part H . The AeroLogix GeoStar sUAS is seeking exemption from the

requirements of an Airworthiness Certificate. If granted, the exemption will nullify the requirements cited above.

GeoStar sUAS flight operations under COA 2014

- CSA

- 35 pres cribe maintenance and maintenance record

keeping in the following manner:

“... Software and hardware changes should be documented as part of the normal maintenance procedures. Software changes to the aircraft and control station as well as hardware system ch anges are classified as major changes unless the agency has a formal process, accepted by the FAA. These changes should be provided to the UAS Integration office in summary form at the time of incorporation. ”

“...All previously flight proven systems to incl ude payloads, may be installed or removed as required, and that activity recorded in the unmanned aircraft and ground control stations logbooks by persons authorized to conduct UAS maintenance Describe any payload equipment configurations in the UAS logboo k that will result in a weight and balance change, electrical loads, and or flight dynamics, unless the agency has a formal process, accepted by the FAA.”

“...For unmanned aircraft system discrepancies, a record entry should be made by an appropriately rat ed person to document the finding in the logbook. No flights may be conducted following major changes, modifications or new installations unless the party responsible for certifying airworthiness has determined the system is safe to operate in the

NAS and a new AWR is generated, unless the agency has a formal process, accepted by the FAA. The successful completion of these tests must be recorded in the appropriate logbook, unless the agency has a formal process, accepted by the FAA.”

AeroLogix intends to opera te the identical GeoStar sUAS system under similar operational and airspace conditions as

previously vetted and approved by the FAA in COA 2014

- CSA

- 35. We respectfully request the same authorizations with

regards to UAV Maintenance. AeroLogix is the original designer and builder of the GeoStar UAV and intimately familiar

with its construction and maintenance. All GeoStar maintenance will be performed by AeroLogix personnel.ACI_201501 14 _333 

### January 2015 44 

### SECTION I V

- SUMMARY STATEMENTS

Equivalent Safety

The Congressional mandate in Section 333 of the Reform Act allows a limited introduction of commercial

Unmanned Aerial Systems (UASs) into the national airspace system in advance of permanent rulemaking, if it can be

accomplished safely. As summarized in this document, Aer oLogix has designed the GeoStar sUAS with a set of

innovative safety features and a focus on systems redundancy that few sUAS s can match . AeroLogix seeks to maximize

the overall safety potential of a fixed

- wing sUAS by both technical achievement and operational professionalism. We

respectfully petition the FAA to consider AeroLogix and the GeoStar sUAS as a professional sUAS operation, previously

vetted via the public

- use COA process and having already demonstrated safe integration of GeoStar sUAS op erations into

the National Airspace System in 2014. The FAA and general public can have confidence that the operations will achieve

an equivalent or greater level of safety as that demonstrated by conventional aerial survey providers

.

Public Benefit

The AeroLogix GeoStar sUAS concept began as means to economically serve the aerial survey needs of a rural,

southern Minnesota county. On

- demand aerial survey by conventional means is a costly undertaking and beyond the

economic re ach of many public and p rivate entities

. The success of the GeoStar sUAS quickly demonstrated that high

resolution GIS imagery and survey grade modeling products were now affordable thanks to the innovations and cost

savings derived from using a UAS. The GeoStar sUAS can delive r small scale collections, specifically tailored to each

project or need and at an afford able cost. In many cases, these benefits were simply not attainable until now. As

highlighted earlier, many publicly funded users of conventional aerial survey servi ces were immediately interested in the

cost benefit and operational flexibility demonstrated by the AeroLogix GeoStar sUAS. The following public entities have

expressed interest and/or directly requested GeoStar sUAS services:

- US Department of Agricultu re/University of Minnesota clover crop research project.

- US Fish and Wildlife Service

- Minnesota Department of Transportation (3 projects)

- Minneso ta Department of Soil and Water

- Scott County, Ravine Survey

- Dakota County, Vermillion River Survey

- Minnesota State University Mankato, GIS Department

- University of Minnesota, Aerospace Engineering Dept., Graduate Student Mentorship Program.

A Section 333 exemption would allow much greater flexibility to service these and other publicly funded users of aerial

survey services. The economic benefit potential to the public is significant.ACI_201501 14 _333 

### January 2015 45 

### From an environmental standpoint, the GeoStar sUAS provides numerous benefits over conventional providers of

aerial survey . Being electric powered, the GeoStar U AV is nearly silent when flying at normal collection altitudes. It also

operates at a higher altitude than many other sUAS systems that seek similar approval for aerial imaging. Once airborne,

it is difficult to distinguish the GeoStar UAV from a convent ional aircraft. It does not have the menacing presence of

many sUASs but rather displays a graceful, soaring character in flight. Th ese features combine to make it unobtrusive to

residents, livestock and wildlife in the rural areas contemplated for opera tions. The GeoStar sUAS utilizes only a small

gasoline

- powered generator in the field for power. Burning small amounts of unleaded gasoline, the volume of pollutants

is significantly less than that of a conventional aircraft burning leaded gasoline or je t fuel. With electric power, the

GeoStar will never deposit pollutants on lakes, farmland or natural areas.

Natural disaster response is another useful public application of the GeoStar sUAS. In the spring and early

summer, many areas of southern Min nesota and the Minnesota River valley fac e flooding due to extreme winter

snowfall s

. Tornados and other severe weather conditions strike without warning, causing wide

- spread devastation. In

situations like th ese, t he GeoStar sUAS can be rapidly dispatched to rapidly produce imagery and terrain modeling

products to support critical public agency response to such disasters.

AeroLogix submits that many aspects of t he GeoStar sUAS are of significant public benefit . A Section 333

exemption will create the opportunity for many more public entities to enjoy the benefits of affordable and efficient aerial

survey.ACI_201501 14 _333 

### January 2015 46 

### Summary for The Federal Register

Specific Rules Sought For Exemption

AeroLogix Consulting Inc., a Minnesota based builder and operator of advanced Small Unmanned Aerial Systems (sUAS)

, is seeking an exemption pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

. AeroLogix is requesting exemption from t he followi ng regulations un der 14 CFR:

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1) Certifications Required 14 CFR § 45.23 Display of marks; general. 14 CFR § 45.25 Location of marks on fixed

- wing aircraft.

14 CFR § 45.29 Size of mark s. 14 CFR § 61.113 Private Pilot Privileges and Limitations: Pilot In Command 14 CFR § 61.133 Commercial Pilot Privileges and Limitations. 14 CFR § 91.7 (a) Civil Aircraft Airworthiness 14 CFR § 91.9 (b)(2) Civil Aircraft Flight Manual in the Aircraft 14 CFR § 91.121 Altimeter Settings 14 CFR § 91.151 (a)(1) Fuel Requirements for Flight in VFR Conditions. 14 CFR § 91.207 (a)(1) Emergency Locator Transmitters (ELTs). 14 CFR § 91.307 (a) Parachutes and Parachuting 14 CFR § 91.405 (a) Maintenance Required 14 CFR § 91.407 (a)(1) Operation After Maintenance, Preventative, Rebuilding or Alteration 14 CFR § 91.409 (a) (1)(2) Inspections 14 CFR § 91.417 (a)(b) Maintenance Records

AeroLogix intends to commercially operate the GeoStar sUAS in rural areas for public and private customers. The

GeoStar sUAS performs aerial survey to produce imagery and terrain modeling products useful in applications ranging

from civil engineering, land and water resour ce management, environmental research, disaster response, agriculture and

many others useful applications. The FAA has previously approved AeroLogix and the GeoStar sUAS for public

operations under FAA Certificate of Waiver or Authorization (COA) 2014

- CSA

- 35. This new exemption under Section

333 of the FAA Modernization and Reform Act of 2012 will permit AeroLogix to serve both public and private entities

with safe and affordable aerial survey services . The FAA and general public can have confidence that the operations will

achieve an equivalent or greater level of safety as that demonstrated by conventional aerial survey providers

.