GE Aviation

PROPRIETARY INFORMATION – GE CONFIDENTIAL 

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GE Aviation Systems LLC 

sUAS Airworthiness Exemption Petition

For

Federal Aviation Administration (FAA) 

Modernization and Reform Act (FMRA)

Sec 333 Exemption

26 June 2015

Publication No: GE 333 Exemption Request.Docx

Point of Contact:

Mike Feldmann

GE Aviation

Telephone (616) 241-8847

GE Aviation Systems LLC

3290 Patterson Ave. SE 

Grand Rapids, Michigan 49512

geaviation.com

Copyright 2015 General Electric Company, U.S.A. 
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June 4, 2015

RE: GE Aviation Systems sUAS Airworthiness Exemption Petition for Federal Aviation 

Administration (FAA) Modernization and Reform Act (FMRA) Sec 333 Exemption

Gentlemen:

GE Aviation Systems, LLC, hereafter “‘GE”, hereby petitions the FAA for regulatory relief pursuant to Section 333 of PL 112–95, 

Special Rules for Certain Unmanned Aircraft Systems, and 14 CFR §11.81, in order for GE to conduct research and 

development flights with GE small Unmanned Aircraft Systems (sUAS), and to pursue research and development of the those 

sUAS and associated sUAS hardware, systems, sensors, and software within defined areas of operations, secured according 

to GE procedures, in the national airspace (NAS). Attached, therefore, is a request for exemption from airworthiness and 

specific Title 14 CFR sections for the types of sUAS and sUAS operations described in this Section 333 exemption petition.

GE is an avionics manufacturer dedicated to developing aircraft flight systems and processes for the safe deployment of 

manned and unmanned aircraft in the NAS. This petition seeks authorization to operate GE sUAS, carrying developmental 

inactive and active electronic sensor payloads, and configured as surrogates for larger aircraft that would eventually use 

these payloads, within restricted access areas. These areas of operation are on private property, and conducted with the 

permission of the property owner. GE sUAS operations will take place below an altitude of 200 ft. AGL, within specific accessrestricted areas, within Class G airspace, using sUAV operated by qualified GE sUAS pilots, and within Visual Line of Sight 

(VLOS) of the operator and observer. The sUAV contemplated in this proposal are of small size (typical maximum dimension 

of 3ft, and in no cases larger than 6ft) and weight (typically less than 15lb, including payload, and in no cases exceeding 

55lb), capable of relatively slow speeds (typical maximum speeds less than 30kt, and in no cases exceeding 100kt) and, as 

demonstrated in this petition, do not pose a threat to the safety of the NAS, persons on the ground, or national security.

This exemption seeks authorization to conduct Research and Development (R&D) flights according to the terms of this 

petition and the GE General Operations Manual (GE Manual) which is composed of (1) an Operations Manual, (2) Flight

Manuals for each of the GE fleet sUAS by make and model, (3) an Operator Training Manual, and (4) a Maintenance and 

Inspection Manual.

Please note that the GE Manual (including all of the above listed components) are all clearly marked “Confidential” on each 

page, and contain confidential commercial and proprietary information that GE has not, and will not, share with others who 

are not subject to a Non-Disclosure Agreement (NDA). Therefore, the GE Manual (including all components) are not available 

to the public, and contain operating conditions, procedures and other information that is not available to the public, and that 

are protected from public release or disclosure under the Freedom of Information Act 5 USC Sec. 552 et seq.

Why we require an exemption: 

1. Commercial Operations

An exemption is required because GE believes current FAA regulations do not allow for commercial use of sUAS lacking 

airworthiness certificates in the NAS. GE requests an airworthiness exemption for specific types of sUAS described in this 

petition to carry payloads including guidance, navigation, and control packages GE intends to offer as commercial products, 

under the conditions and operating limitations outlined below, and as described in the GE Manual.

2. Research and Development

GE develops guidance, navigation and control systems and software for sUAS, which are used as surrogates for larger 

manned and unmanned aerial vehicles, so that they may takeoff, operate, and land, safely and predictably in the NAS. 

In order to develop and test systems and software for these sUAS under the variety of operational conditions a manned or 

unmanned aircraft will face in the NAS, it is necessary to test various sUAS and sUAS configurations, in different 

environments. 

GE believes FAA Order 8130.34C, Special Airworthiness Certification, Experimental Certificates (SAC-EC) does not authorize the 

necessary variable aircraft characteristics and systems to meaningfully test the responsiveness and functionality of these 

sUAS. 

Therefore, to gain the meaningful data about sUAS features necessary for developing a program for safe and efficient sUAS 

operations, an exemption is required that authorizes R&D: 

a. Across a range of sUAS makes, models and prototypes 

b. In a variety of locations (subject to the restrictions outlined in this petition)

c. For iterating the payload systems and airframes on an ongoing basis. 
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Without this exemption the regulatory requirements for an SAC-EC are overly burdensome because they forbid the 

necessary R&D, i.e. rapid iterations on prototypes. 

Finally, GE believes the SAC-EC does not authorize commercial operations of the type described above, which are required 

for GE R&D.

Regarding the Unmanned Aircraft System

GE is developing a class of sUAS based on Commercial, Off the Shelf (COTS) ”multicopter” parts manufactured primarily by 

3D Robotics, Inc. Additionally, GE operates Parrot SA “Bebop” sUAS, which are unmodified COTS quad copters, used only for 

video recording other GE sUAS flight operations. The performance and performance limitations of multicopters built from 

these parts are well known, and tens of thousands of these types of multicopters have been operated safely for many years.

Further, GE has been developing and safely operating sUAS built from these parts in a controlled, indoor, environment for 

over 6 months. A primary benefit of these indoor operations is that GE has been able to develop and refine comprehensive 

Operations, Flight, Training, and Maintenance Manuals for GE personnel operating and maintaining these sUAS. GE 

maintains these documents according to standard GE practices and process. These same Manuals will be applied to 

outdoor operations being requested by this petition.

The Radio Frequency (RF) spectra used by GE are 2.4GHz COTS flight transmitters/receivers and telemetry links that are all 

compliant with Federal Communications Commission (FCC) requirements. Copies of the FCC approval will be provided upon 

FAA request.

Regarding the Unmanned Aircraft PIC

In accordance with the knowledge requirements in Exemption No. 11062, and as described in detail in the GE Manual, a GE 

Pilot in Command (PIC) must:

1. Be qualified, under the guidance of an FAA certificated private or commercial pilot who is current (operationally, 

medically, and bi-annually) who is a GE employee with applicable experience operating the GE sUAV, and is current in 

accordance with the GE Manual.

2. Have flown and logged a minimum of 50 flight cycles and 10 hours of total time as a sUAS pilot for a given GE sUAS

make and model.

3. Have flown and logged a minimum of 5 hours as UAS pilot with the make and model of the GE sUAS, as well as having 

conducted three take-offs and landings with that aircraft make and model, in the preceding 90 days.

Also as described in detail in the GE Manual, a GE Flight Operation Observer (FOO) will be trained to understand and interact 

with the PIC.

Documentation for PIC and FOO qualification and currency will be maintained as per the GE Operating Manual and will be 

available upon the FAA’s request.

Regarding the Operation of the Unmanned Aircraft

Section 333 describes seven minimum criteria to determine whether a sUAS may operate safely in the NAS without creating 

a hazard or posing a threat to national security: 

1. Size: GE sUAS are smaller than 6 feet in the largest dimension.

2. Weight: GE sUAS weigh less than 55 pounds, including payloads.

3. Speed: GE sUAS travel at a maximum velocity of 50 knots.

4. Operational Capability: GE sUAS are battery powered and have a maximum flight time of approximately 20 minutes. 

Battery warning alarms are provisioned to alert the PIC and FOO when approximately 30% battery capacity remains. In 

accordance with the GE Manual, landing is to be performed when this, or any other applicable, alarm is triggered. 

Navigational warning alarms are provisioned to alert the PIC and FOO any time navigational accuracy or performance 

is compromised. In accordance with the GE Manual, landing is to be performed when this, or any other applicable, 

alarm is triggered. Command and Control (CC) link warning alarms are provisioned to alert the PIC and FOO any time CC 

link is compromised. GE sUAS are provisioned to auto-land anytime CC is compromised. Additionally, GE sUAS are 

provisioned with an RF-activated “kill switch” that stops the electronics and motors, terminating flight. 

5. Operation in close proximity to airports: GE sUAS will not be operated within 5 nautical miles of any airport.

6. Operation in close proximity to people: GE sUAS will not be operated in close proximity to people. Non-essential 

personnel are precluded from the area of operation in accordance with the GE Manual.

7. Operation within visual line of sight (VLOS): The PIC and/or FOO will maintain VLOS with each other and the sUAS, and a 

“Geo Fence” that restricts operation within the geographic boundaries (nominally within a 1500 foot radius of the 

takeoff point) of the operating area will be enabled, in accordance with the GE Manual. GE sUAS will be operated in 
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daylight Visual Meteorological Conditions (VMC), and will not be operated when flight visibility is less than 1 nautical 

mile, or with cloud clearance of less than 500 feet below or 2000 feet horizontally. Additionally, the airspace used will be 

wholly within the underlying property owner’s boundaries, and with his written consent.

GE’s proposed sUAS are of a type and scale that meet these criteria, GE sUAS operations, training, and maintenance and 

inspection procedures are in place and validated, and are equivalent to those for which FAA has recently granted Sec 333 

exemptions, and, similarly, are not anticipated to create a hazard to users of the NAS, persons on the ground, or pose a 

threat to national security.

Additionally, GE does not intend to conduct sUAS operations which have requirements to notify the Flight Standards District 

Office (FSDO).
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Information Supporting this Petition as Specified in 14 

CFR §11.81

This section responds to the specific requirements of 14 CFR Sec 11.81. The attached Exhibit A

“Information Supporting Petition” presents an analysis of 8130.34C and ancillary CFR to demonstrate either direct 

compliance or alternative method of compliance for each regulatory exemption requested.

a. Mailing address and other contact information such as a fax number, telephone number, or email address copy.

GE Aviation Systems, LLC

ATTN: Mike Feldmann, Chief Engineer

3290 Patterson Ave SE

Grand Rapids MI

Email: mike.feldmann@ge.com

(616) 241-8847

b. The specific section or sections of 14 C.F.R. from which GE seeks an exemption:

Part 21 (Subpart H) Airworthiness Certification 

Part 21 (Subpart H) Experimental Category

Part 47 Aircraft Registration and Marking

§61 Requirements for certification of instructors for crew training

§91.103(b)(2) Preflight Action

§91.105 Flight Rules

§91.109 Flight Instruction

§91.119 Minimum Safe Altitudes

§91.121 Altimeter Settings

§91.151 Fuel Requirements for Flight in VFR Conditions

§91.203 Civil Aircraft: Certifications Required

§91.405 Maintenance Required

§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration

§91.409 Inspections

§91.417 Maintenance records

c. The extent of relief GE seeks, and the reason GE seeks the relief

Part 21 (Subpart H) Airworthiness Certification; Exemption is necessary because GE sUAS are not hazardous, carry no 

persons, and operate under a controlled environment in accordance with approved GE training and procedures.

Part 21 (Subpart H) Experimental Category; Experimental Category does not authorize the necessary rapid modifications of 

aircraft characteristics and associated systems to operate and test these sUAS. Therefore, to gain meaningful data about 

the necessary features for safe and efficient sUAS operations, an exemption is necessary: 

(1) to operate a range of sUAS makes, models and prototypes,

(2) in a variety of locations (subject to the restrictions outlined in this petition), 

(3) to be permitted to adjust the systems and airframes tested on an ongoing basis, and 
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(4) for research and development. 

Part 47 Aircraft Registration and Marking; GE sUAS will be registered in accordance via Aircraft Registration Application, AC 

Form 8050-1, and marked in accordance, as large as practical. 

§61 Requirements for certification of instructors for crew training; Exemption is needed because GE sUAS operations are 

conducted by personnel trained in accordance with approved GE training and procedures.

§ 91.103(b)(2) Preflight Action; GE sUAS are pre-flight inspected in accordance with approved GE training and procedures.

§ 91.105 Flight Rules; Exemption is needed because there is no flight crew. PIC and FOO are operators conducting flight 

operations from the ground in in accordance with approved GE training and procedures.

§ 91.109 Flight Instruction; Exemption is needed because not all PIC will be private pilots. However, they will be trained by a 

private pilot in accordance with approved GE training and procedures.

§91.119 Minimum Safe Altitudes; Exemption is necessary because GE sUAS will be operated lower than 500 feet AGL.

§ 91.121 Altimeter Settings; Exemption is needed because GE sUAS barometric altimeters are not provisioned to 

accommodate altimeter settings. GE sUAS use additional sensors such as optical and sonar range finders, and other 

electronic means, to perform altimetry.

§ 91.151 Fuel Requirements for Flight in VFR Conditions; Exemption is necessary because GE sUAS are battery-powered and 

provisioned with adequate warning of low battery conditions to allow safe landing. 

§ 91.203 Civil Aircraft: Certifications Required; Exemption is necessary because airworthiness certification of GE sUAS is 

overly burdensome for the minimal hazard presented, the procedural airworthiness assurance afforded by the GE Manual, 

and the limited flight activities that will be performed.

§91.405 Maintenance required; §91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration; 

§91.409 Inspections; §91.417 Maintenance records; Exemption is needed because there are no FAA certified maintainers or 

inspectors for these aircraft. GE is most experienced with these aircraft and has developed the GE Manual to ensure 

equivalent level of safety is achieved. 

In summary, a Section 333 exemption is required because current FAA regulations do not allow commercial use of sUAS in 

the NAS, or for research and development using sUAS. GE requests an airworthiness exemption for the specific types of 

sUAS described in this petition to carry inert payloads, e.g. sensor packages, under the conditions and operating limitations 

outlined below and described in the GE Manual. In addition, GE is developing sUAS and sUAS software, including guidance, 

navigation, and control software for small commercial UAVs, so that sUAV may fly safely and predictably in the NAS. In order 

to develop and test these sUAS under the variety of operational conditions that a sUAS will face in the NAS, it is necessary to 

test variations on aircraft characteristics, operating systems, and management systems in different environments. 

d. The reasons why granting GE’s request would be in the public interest; that is, how it would benefit the public as a whole

GE research and development is designed to establish a reasonable methodology to test specific types and platforms of 

sUAS for purposes of developing GE guidance, navigation and control systems, in a variety of environments, to allow the 

resultant systems to be used in both military and civil applications that enable and enhance the safe and efficient operation

of all types of aircraft in the NAS. 

The outputs of safe, reliable, and regulatory-compliant operations of sUAS provide economic benefits to stakeholders at 

every level, both public and private. Grant of this petition would enable the research and operational development of 

necessary industry infrastructure to enable the safe and efficient acceleration of these significant public benefits to the 

United States public.

e. The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level 

of safety at least equal to that provided by the rule from which GE seeks the exemption GE operations will provide a 

level of safety that is equivalent to current aviation standards.

Equivalent Level of Safety

GE’s safety procedures, risk assessments, and flight operations standards are described in detail in the accompanying GE 

Operations Manual. In brief, the following procedures that apply during operations conducted under this exemption request, 

establish an equivalent level of safety (ELOS) as follows:
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1. The GE sUAS weigh less than 55 pounds, are battery powered, carry inert payloads, and therefore constitute minimal 

energy hazards.

2. All GE sUAS will be U.S. registered and display marks either in accordance with 14 CFR Part 45, Subpart C, or be as large 

as practical.

3. GE sUAS operations under this exemption will be conducted within unaided VLOS of the PIC or least one observer, at 

less than 200 feet AGL, within Class G airspace. Operations in Class A, B, C, or D airspace will not be performed.

4. GE operations will be conducted in defined regions and over property authorized for this use by the landowner. All 

operations will remain within the geographic boundaries of the operating area.

5. GE sUAS operations under this exemption will be conducted under the supervision of a designated PIC who has final 

responsibility for the operation, and in accordance with 14 CFR 91.3. All GE sUAS PIC and FOO must have completed 

training on the normal, abnormal, and emergency procedures in the GE Manual and demonstrated proficiency with the

sUAS being operated.

6. Operators and engineers will maintain the GE sUAS system in a condition for safe operation according to the GE Manual 

and associated manufacturer’s maintenance manuals, including pre-flight and post-flight inspections.

7. The PIC and FOO will maintain situational awareness and perceive, process, and perform risk management prior to and 

during each operation as described in the GE Manual.

8. The PIC will terminate the operation in accordance with the GE Manual if hazards that cannot be acceptably otherwise 

mitigated are observed.

9. GE sUAS will safely stop operating and/or auto-land if the Command and Control link is lost.

10. For each GE sUAS, the PIC will have the ability to force a controlled landing at any time.
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Summary suitable for FAA publication in the FEDERAL 

REGISTER

Petitioner: GE Aviation Systems, LLC.

Description of Relief Sought: 

Sections of 14 CFR 21; 47, 61, 91, and ancillary sections. 

Petitioner seeks to be exempt from the requirements of Part 21 (Subpart H), Part 47, §61,§91.103(b)(2), §91.105, §91.109, 

§91.119, §91.121, §91.151, §91.203, §91.405, §91.407, §91.409,§91.417

GE requests this regulatory relief in order to conduct commercial R&D using of a class of sUAS over private property subject 

to operating procedures that meet an equivalent level of safety as those that FAA requires for similar operations in manned 

aviation.

Please see the introduction to this exemption request and the attached Petition for additional information that supports this

request.

Some GE partners and clients operate manufacturing and testing facilities outside the United States. Nonetheless, GE pilots 

operating in any jurisdiction will operate according to the standards promulgated by the FAA and the restrictions outlined 

here and in the GE Manual.

GE seeks this exemption to conduct commercial operations and supporting R&D using sUAS within specified areas in the 

NAS. Without this exemption, sUAS innovation will be suppressed, the public economic benefits derived from increased sUAS 

development will be denied, and the Congressional directive to accelerate the integration of UAS into the NAS will be 

impeded. GE sUAS physical and operational characteristics are compliant with those described in the FMRA and FAA’s 

guidance for Sec 333 exemptions. GE respectfully requests that the FAA grant its petition for exemption from airworthiness, 

COA, and COW requirements.
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Attached hereto and submitted as a confidential document is GE’s Operations Manual. We respectfully submit that good 

cause exists so that this confidential manual does not need to be published in the Federal Register.

Please do not hesitate to contact me if you have any questions or concerns.

Very Respectfully Yours,

Mike Feldmann

GE Aviation Systems, LLC

3290 Patterson Ave SE

Grand Rapids MI

Email: mike.feldmann@ge.com

(616) 241-8847