## GE Aviation

PROPRIETARY INFORMATION

– GE CONFIDENTIAL

The information contained in this document is GE proprietary information and is disclosed in confidence. It is the property o f GE and shall not be used, disclosed to others or reproduced without the express written consent of GE, including, but without lim itation, it is not to be used in the creation, manufacture, development, or derivation of any repairs, modifications, spare p arts, designs, or configuration changes or to obtain FAA or any other government or regulatory approval to do so. If consent is giv en for reproduction in whole or in part, this notice and the notice set forth on each page of this document shall appear in any such reproduction in whole or in part. 

# GE Aviation Systems LLC sUAS Airworthiness Exemption Petition

F or Federal Aviation Administration (FAA)
Mode rnization 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.2 of 6 PROPRIETARY INFORMATION

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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, Sp ecial 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 h ardware, 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 t ypes 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 petitio n 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 opera tion 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 access

restricted areas, within Class G airspace, using sUAV operated by qualified G E 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 speed s less than 3 0kt , 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 groun d , 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 e ach 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 exemptio n:



### 1. Commercial Operation s

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 describ ed 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 Developmen t

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 81 30.34C, Sp ecial Airworthiness Certification, Experimenta l 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. A cross a range of sUAS makes, models and prototypes
b. I n a variety of locations (subject to the restrictions outlined in this petition)

c. F or iterating the payload systems and airframes on an ongoing basis.3 of 6 PROPRIETARY INFORMATION

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Without this exemption the regulatory requirements for an SAC

- EC are overly burdensome because they f orbid the necessary R &D, i.e. rapid iteration s 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 Shel f (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 performan ce 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 contr olled, 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/re ceivers 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 i n 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 l ogged a mi nimum 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 Operati on 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 dim ension.


### 2. We ight: GE sUAS weigh less than 5 5 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 warn ing 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 prov isioned 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 alar ms 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, t erminating 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

personne l are pr ecluded 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 in4 of 6 PROPRIETARY INFORMATION

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daylight Visual Meteorological Conditions (VMC), and will not be operated when flig ht 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, simi larly, 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 Off ice (FSDO).5 of 6 PROPRIETARY INFORMATION

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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 (Subpa rt 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 In struction

§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 maintena nce, 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, car ry 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, and6 of 6 PROPRIETARY INFORMATION

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(4) for research and developmen t

. 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 trai ning; 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 pr ocedures.

§ 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 th an 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 mea ns, 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: C ertifications Required ; E xemption is necess ary 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 wi ll 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
i nspectors 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 commer cial 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 limi tations 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 wh y 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 developi ng 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.

T he 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 a t 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 oper ations 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:7 of 6 PROPRIETARY INFORMATION

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### 1. The GE sUA S 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 con ducted 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 accept ably 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.8 of 6 PROPRIETARY INFORMATION

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# Summary suitable for FAA publicat ion 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 e quivalent 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 clie nts 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 seek s 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 deni ed, 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 respectfull y requests that the FAA grant its petition for exemption from airworthiness, COA, and COW requirements.9 of 6 PROPRIETARY INFORMATION

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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 confiden tial 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