1001 Pennsylvania Avenue, NW, Washington, DC 20004

- 2595  p202 624

- 2500  f202 628

- 5116

Marc L. Warren

(202) 624

- 2531

mwarren@crowell.com

September 30 , 2015

VIA FDMS

Ms. Cheryl Collins

Program Manager, Docket Operations

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building Ground Floor, Room W12

- 140

Attn: FAA Dockets

Washington, DC 20590

Re: General Electric Global Research

– Petition for Exemption

Dear Ms. Collins :

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) 1

and 14 C.F.R. Part 11, General Electric Global Research ( “ GEGR ” )

, an unincorporated operating

component of General Electric Company (“ GE ”)

, petitions for an exemption from the Federal

Aviation Regulations identified herein to authorize GE GR to operate small unmanned aircraft

systems (“sUAS”) for research and development on sensors and capabilities for aerial data

collection and for aerial data collection to support GE business activities

. 2 GE GR ’ s sUAS

o perations will be conducted under the safeguards described in this petition and as may be

further established by FAA.

FAA has now issued over 1, 7 00 Section 333 exemptions to various commercial

enterprises for sUAS applications ranging from aerial photography and cinematography to

precision agriculture and flare stack, bridge and tower inspections. 3 Indeed, FAA has granted

1 Pub. L. No. 112

- 95, § 333, 126 Stat. 76.

2 This exemption request is based on the information provided in this petition and the user

manuals for GE GR ’s Altavian Nova F6500, Altavian Nova R8400, AscTec Falcon 8, DJI S1000, DJI Phantom 3, DJI

Inspire, and Allied Drones AT28 sUAS and the Airware Flight Operations Manual and Regulatory Refer ence Guide

(collectively, the “Manuals”)

, copies of whic h are either already on file with FAA or will be shortly

. See, e.g., In the

Matter of the Petition of Blue

- Chip Unmanned Aerial Solutions, Inc., Grant of Exemption No. 11172A (Jul. 20, 2015 )

, Docket No. FAA

- 2014

- 0787 ( DJI Inspire 1, DJI S1000, DJI Phantom 3, and Altavian Nova F6500) ; In the Matter of the

Petition of Trihydro Corporation, Grant of Exemption No. 11735 (Jun. 2, 2015), Docket No. FAA

- 2015

- 0854 (Altavian

Nova R8400); In the Matter of t he Petition of Unmanned Experts, Inc., Grant of Exemption No. 12075 (Jul. 17,

2015), Docket No. FAA

- 2015

- 1370 (AscTec Falcon 8); a nd In the Matter of the Petition of Wild Rabbit Productions

,

LLC

, Grant of Exemption No. 11440A ( Jul

. 10

, 2015), Docket No. FAA

- 2015

- 0168 ( Allied Drones sUAS )

.

3 See FAA, Authorizations Granted Via Section 333 Exemptions (rev. Sept

. 30 , 2015 )

, https://www.faa.gov/uas/legislative_programs/section_333/

.FAA Dockets

September 3 0 , 2015

Page 2

hundreds of Section 333 exemption s for aerial data collection in circumstances that are similar

in all material respects to those propose d here. 4 In issuing those exemption s and other S ection

333 g rants

, FAA found that “the enhanced safety achieved using an unmanned aircraft (UA)

with the specificati ons described by the petitioner

... gives the FAA good cause to find that the

UAS operation enabled by this exemption is in the public interest

. ” 5 The same public interest

and safety justifica tions apply to GE GR ’s petition, and should enable FAA to grant it on an

expedited basis.

I. Petitioner

Founded in 1892, GE is one of the world’s largest infrastructure and technology

companies, with operating divisions focusing on, among other areas, power generation and

distribution, healthcare equipment and systems, avi ation propulsion systems, railway

locomotives, and oil and gas extraction and processing systems. GEGR has been a primary

research organization for the Company for over one

- hundred years; scientists and engineers

employed by GEGR work across a broad spectrum of technologies to develop innovative

solutions to technical challenges across the range of GE businesses and other advanced

technology areas.

All communications regarding GE GR ’s petition should be directed to:

Marc L. Warren

Crowell & Moring LLP

1001 Pennsylvania Ave NW

Washington, DC 20004

mwarren@crowell.com w ith a copy to: Donald S. Ingraham

Legal Counsel

GE Global Research

One Research Circle

Niskayuna, New York 12309

Ingraham@ge.com

II. Section 333

GE GR ’s petition is consistent with Congress’ s goal set forth in Section 333 of the FMRA,

which directs the Secretary of Transportation to consider whether certain UAS may operate

safely in the national airspace system ( “ NAS ” ) before completion of the rulemaking s required

under Section 332 of th at legislation

. In making this determination, the Secretary is required to

deter mine which types of UAS do not create a hazard to users of the NAS or the public or pose

a threat to national security in light of the following: (1 ) t he UAS’ size, weight, speed, and

4 See, e.g., In the Matter of the Petition of AUV, LLC , Grant of Exemption No. 12078 ( Jul

. 17 , 2015),

Docket No. FAA

- 2015

- 1170 (“Exemption No. 12078”); In the Matter of the Petition of Vertical Access LLC , Grant of

Exemption No. 11943 (Jun. 30 , 2015), Docket No. FAA

- 2015

- 1406 (“Exemption No. 11943 ”) ; and In the Matter of

the Petition of RTI Group , LLC, Grant of Exemption No. 11946 ( Jun

. 30 , 2015), Docket No. FAA

- 2015

- 1455

(“Exemption No. 11946 ”)

.

5 See, e.g., Exemption No. 12078 at 2; Exemption No. 11943 at 2; and Exemption No. 11946 at 2.FAA Dockets

September 3 0 , 2015

Page 3

operational capability; (2 ) o peration of the UAS in close proximity to airports and populated

areas; and (3 ) o peration of the UAS within visual line of sight of the operator. 6 To implement

Section 333, FAA has the authority to issue exemptions from its safety regulations and

minimum standards when the Administrator decides a requested exemption is in the public

interest. 7

GE GR ’ s proposed s UAS operations meet the requirements of, and qualify for expedited

approval under, Section 333. GE GR ’ s sUAS weigh less than 55 pound s , will operate at less than

400 feet above ground level ( “ AGL ” )

, within visual line of sight ( “ VLOS ” )

, at speeds of no more

than 87 knots, and will generally comply with the same conditions and limitations FAA

established in issuing previous Section 333 g rants

. 8 As further explained in Section IV, infra , all

of GE GR ’s sUAS will use the Airware flight control system.

Operations conducted under these safeguards will provide at least an equivalent level of

safety compared to the current regulatory structure. More over, G E GR ’ s operations will not

“create a hazard to users of the national airspace system or the public or pose a threat to

national security” due to the size of the sUAS and the restricted areas in which they will

operate. 9

III. Regulations from Which an Exemption is Requested

GE GR requests an exemption from the following regulations to the extent necessary for

GE GR to conduct the operations described in this petition :

 14 C.F.R. § § 61.23(a) and (c)

 14 C.F.R. §§ 61.101(e)(4) and (5)

 14 C

. F

. R

. § 61.113(a)

 14 C

. F

. R

. § 61. 315 (a)

 14 C.F.R. § 91. 7(a)

 14 C.F.R. § 91.119 (c)

 14 C.F.R. § 91.121

 14 C

. F

. R . § 91.151(a) (1)

 14 C

. F

. R . § 91.405(a)

 14 C

. F

. R . § 91. 407(a)(1)

 14 C

. F

. R . §§ 91. 409(a) (1) and (2)

 14 C

. F

. R . §§ 91. 417(a) and (b)

6 FMRA § 333(a).

7 See 49 U.S.C. § 106(f) and 49 U.S.C. § 44701(f).

8 See supra note 3

.

9 See, e.g., In the Matter of the Petition of Astraeus Aerial

, Grant of Exemption No. 11062 (Sep t . 25,

2014), Docket No. FAA

- 2014

- 0352 (“Exemption No. 11062”) at 8 ( citing FMRA § 333(b)).FAA Dockets

September 3 0 , 2015

Page 4

The following subsections describe GE GR ’s request for an exemption from each of these

regulations and demonstrate how GE GR ’ s operations will provide for at least an equivalent

level of safety compared to the current regulatory structure that applies to manned aircraft

.

A. 14 C.F.R. §§ 61.23(a) and (c)

– Medical certificates: Requirement and

duration

Sections 61.23(a) and (c) generally require pilots of manned aircraft to hold a FAA

medical certificate in ord er to exercise pilot privileges

. As of March 24, 2015, however, FAA

determined as a matter of policy that operators hold ing a valid driver’s license in lieu of a third

class medical certificate may conduct commercial sUAS operations under a Section 333 grant

. 10

Accordingly, GE GR requests an exemption from these provisions to the extent necessary to give

GE GR the same relief from medical certificate requirements that FAA has afforded to hundreds

of other operators pursuant to Section 333

. 11

B. 14 C.F.R. §§ 61.101(e)(4) and (5) ; 61.113(a); and 61.315(a)

– P ilot P rivileges

and L imitations

Section 61.113(a) limits private pilots to conducting non

- commercial operations.

Similarly, Sections 61.101(e)(4) and (5) prohibit a recreational pilot from ac ting as pilot in

command of an aircraft for compensation or hire or in furtherance of a business. Section

61.315(a) authorizes a sport pilot certificate holder to act as pilot in com m and of a light

- sport

aircraft, subject to certain restrictions specified in Section 61.315(c), including a prohibition on

doing so for compensation or hire or in furtherance of a business, among other restrictions.

FAA has already determined

, however, that a private

, recreational or sport pilot certificate is

sufficient to conduct commercial sUAS flights in a wide variety of operational environment s

. 12

Since GE GR will be conducting its sUAS operations for compensation in further ance of its

business

, GE GR requests an exemption from these provisions to the extent necessary. GE GR

notes that FAA has provide d such relief to hundreds of other Section 333 operators. 13

Consistent with the operating conditions and limitations specified in similar Section 333

g rants, 14 GE GR will utilize only pilots holding a FAA airline transport, commercial, private,

recreational, or sport pilot certificate and at least a valid U.S. driver’s license . The sUAS will be

operated with in VLOS of the pilot

- in

- command (“ PIC ”) at all times , and all operations will utilize

10 See, e.g., In the Matter of the Petition of EnviroMINE, Inc. , Grant of Exemption No. 11227 (Mar.

24, 2015), Docket No. FAA

- 2014

- 0678 at 4, 8; see also FAA, FAA Summary Grants Speed UAS Exemptions (Apr. 9,

2015), https://www.faa.gov/news/updates/?newsId=82485

.

11 See supra note 3

.

12 Id.

13 Id

.

14 See, e.g

. , Exemption Nos. 12078, 11943

, and 11946

.FAA Dockets

September 3 0 , 2015

Page 5

a visual observer ( “ VO ” ) , who wil l be able to communicate verbally with the PIC at all times

during the operation. And because the area of operation will be controlled and restricted in

accordance with the safeguards contained in the Manual s and the FAA

- approved conditions

and limitations described in Section VI, infra , permitting the sUAS operations as requested

would provide for the level of safety otherwise achieved through these Part 61 provisions

. Accordingly, grant of the requested exe mption, subject to the conditions and limitations

specified herein, would not adversely affect the safety of the NAS.

C. 14 C.F.R. § 91.7(a)

– Civil aircraft airworthiness

Section 91.7(a) prohibits any person from operating a civil aircraft unless it is in an

airworthy condition. FAA has stated that no exemption is required for 14 C.F.R. § 91.7(a) to the

extent that the airworthiness certificate requirements of Part 21 15 are waived or inapplicable.

Such airworthiness certificate requirements are inapplicable here, i nsofar as GE GR ’ s sUAS

provide for an equivalent level of safety when compared to manned aircraft, consistent with

the relevant language of the FMRA and the preceden t FAA has established under Section 333

. 16

D. 14 C.F.R. § 91.119 (c)

– Min imum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically,

Section 91.119(c) provides that except when necessary for takeoff or landing, no person may

operate an aircraft below an altitude of 500 feet above the surface except over open water or

sparsely populated areas and that in such cases, the aircraft may not be operated closer than

500 feet to any person, vessel, vehicle or structure. As detailed in previous Section 333 g rants

, however, FAA has determined that adherence to certain safety measures is sufficient to

warrant an exemption from Section 91.119(c) for sUAS operations

. 17 Consistent with the relief

provided to other sUAS operators under Section 333

, GE GR requests an exemption to the

extent necessary to permit GE GR to operate below an altitude of 500 feet AGL and closer than

500 feet to any person, vessel or structure. An equivalent level of safety will be achieved given

the size, weight and speed of GE GR ’ s sUAS, as well as the location s where it will be operated

( i.e., nowhere near other aircraft)

. In addition, c onsistent with t he flexibility that FAA has

already provided to other Section 333 operators for aerial data collection

, 18 GE GR requests

permission to operate a minimum distance of 200 feet from any non

- participating persons so

15 FAA has concluded that no exemption from Part 21, Subpart H (Airworthiness Certificates) is

needed if the agency makes a finding under the FMRA that the UAS selected provides an equivalent level of safety

when c ompared to aircraft normally used for the same application. As t hese criteria are met here, no exemption is

needed. See

, e.g., Exemption No. 11062 at 13

- 14, 22. But to the extent FAA determines that there are some

characteristics of GE GR ’s sUAS that may n ot meet this standard , an exemption is requested.

16 See, e.g., id.

17 See, e.g., supra note 3

.

18 See supra note 4

.FAA Dockets

September 3 0 , 2015

Page 6

long as sufficient barriers exist to protect such persons from debris in the event of an

accident. 19

E. 14 C.F.R. § 91.121

– Alti meter Settings

Section 91.121 requires each person operating an aircraft to maintain cruising altitude

by reference to an altimeter that is set “to the elevation of the departure airport or an

appropriate altimeter setti ng available before departure

. ” Since GE GR ’ s sUAS will not b e

equipped with a typical barometric altimeter, GE GR requests relief from this provision

consistent with the relief that FAA has already granted to other sUAS operators flying at

similarly low altitudes. 20 GE GR will operate the sUAS within VLOS at or below 400 feet AGL and

provide altitude information to the PIC via a digitally encoded telemetric data feed that

downlinks from the aircraft to a ground

- based on

- screen display. The altitude information will

be generated by equipment installed on the sUAS, and pri or to each flight a zero altitude

initiation point will be established and confirmed for accuracy by the PIC.

F. 14 C.F.R. § 91.151(a)

– Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “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 minut es; or (2) At night, to fly after that for at least 45

minutes.” But provided certain operational parameters are established, FAA has found that

good cause exists for granting exemptions from this provision for operations in a multitude of

contexts

. 21

GE GR will be operating a less than 55

- pound sUAS in tightly

- controlled en vironment s at

speeds below 87 knots and within VLOS. Combined with the fact that GE GR will not conduct

operations unless its sUAS has enough available power for the intended mission

, and will not

continue unless there is at least five minutes of power remaining

, relief from Section 91.151(a)

is warranted

, in accordance with the conditions and limitations specified in Section VI, infra

.

19 See In the Matter of the Petition of Team 5, LLC , Grant of Exemption No. 11158 (Jan. 29, 2015),

Docket No. FAA

- 2014

- 0783, at 16

- 17; In the Matter of the Petition of Picture Factory, Inc. , Grant of Exemption No.

11178 (Feb. 18, 2015), Docket No. FAA

- 2014

- 0794, at 23; In the Matter of the Petition of Shotover Ca mera Systems,

L.P. , Grant of Exemption No. 11159 (Jan. 30, 2015), Docket No. FAA

- 2014

- 0784, at 12; see also FAA Order 8900.1,

Vol. 3, Ch. 8, Sec. 1 (allowing certain relief from 14 C.F.R. § 119(c) in the filming context, including the 200 ft.

minimum dista nce standard requested herein).

20 See supra note 3.

21 Id.FAA Dockets

September 3 0 , 2015

Page 7

G. 14 C.F.R. §§ 91.405(a); 91.407(a)(1); 91.409(a )(1) and (2); and 91.417(a) and

(b): Maintenance Inspections

These provisions require that an aircraft operator or owner “shall have that aircraft

inspected as prescribed in subpart E of this part and shall between required inspections, except

as provide d in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43

of this chapter.

. .,” and that other persons shall inspect or maintain the aircraft in compliance

with Part 43. Under Section 333

, however, FAA has established safet y measures for certain

sUAS operations sufficient to warrant an exemption from these provisions. 22

GE GR will strictly adhere to the maintenance

- and inspection

- related requirements set

forth in its Manual s

, which are consistent with applicable conditions and limitations described

in Section VI, infra

.

IV. Unmanned Aircraft System

GE GR proposes to fly Altavian Nova F6500, Altavian Nova R8400, AscTec Falcon 8, DJI

S1000, DJI Phantom 3, DJI Inspire, and Allied Drones AT28 sUAS. These sUAS are battery

powered vehicles weighing less than 55 pounds that will be flown in accordance with strict

operating safeguards as more fully described in Section VI, infra

, as well as those described in

the Manual s

. T he sUAS will operate at a speed of no more than 87 knots and have the

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

GE GR will incorporate the Airware flight control system into its sUAS. Airware’s systems

are commerci al grade, engineered to enable safe and reliable commercial UAS applications and

have been built from the ground up by leading aerospace engineers consistent with industry

best practices. The system’s safety features include geofencing, a full suite of co ntingency

management functions, user and flight plan management and approval functionality, and many

more. These and other safety features will ensure the safety of persons and property within

and surrounding the limited operating area. In the event the sUAS loses communications or its

GPS signal, it will have the capability to return to a pre

- determined location and land. The sUAS

will also have the capability to abort a flight in the event of unpredicted obstacles or

emergencies. Comprehensive descrip tion s of GE GR ’s sUAS and their specifications and

capabilities are contained in the Manuals

.

As FAA has recognized, the limited weight of less than 55

- pound sUAS significantly

reduces the potential for harm to participating and nonparticipating individuals or property in

the event of an accident or incident, and the risk to an onboard pilot and crew is eliminated

with the use of sUAS. 23

22 Id

.

23 Id.FAA Dockets

September 3 0 , 2015

Page 8

In addition, prior to each flight, the PIC will conduct a pre

- flight inspection of the sUAS,

and maintenance wi ll be performed to address any condition potentially affecting safe

operations. All maintenance and alterations will be documented in the aircraft records. The

safety guidelines specified in the Manuals address the following key areas : ( 1 ) individual par ts

( e.g., remote controller, compass, parameter settings, battery, storage and transportation,

maintenance and upkeep, etc.); (2) flight environment requirements ; ( 3 ) flight warnings ( e.g.,

failsafe and return to home, low battery, vision positioning syste m, transformation function,

etc.) ; (4 ) pre

- flight checklist ; and (5 ) maintenance checks concerning the battery,

transformation sy stem, motors

, and vision positioning system.

V. Unmanned Aircraft PIC

As described above

, the PIC will be a FAA licensed airman with either an airline

transport, commercial, private, recreational, or sport pilot certificate, that holds a current FAA

airman medical certificate or a valid U.S. driver’s license

. The PIC will also meet the flight

review requirements specified in Section 61.56 in an aircraft in which the PIC is rated on his or

her pilot certificate. And, p rior to conducting commercial operations under this exemption, t he

PIC will have accumulated and logged su fficient UAS

- specific flight experience

, including at least

12 hours on its sUAS before being designated to operate it commercially.

In addition, the PIC and the VO will have successfully com pleted a qualification process

and a sUAS flight demonstration administered by a GE GR

- approved and

- qualified pilot.

VI. Operation of the Unmanned Aircraft

GE GR will conduct all flights under the requested exemption subject to the following

conditions and limitations, and as further detailed in the Manual s : 24

A. The sUAS will weigh less than 55 pounds (25 kilograms ), including payload

.

B. The s UA S will not be flown at a ground speed exceeding 87 knots ( i.e. 100 miles per

hour)

.

C. Flights will be operated at an altitude of no more than 400 feet AGL. All altitudes

reported to ATC will be in feet AGL

.

D. The s UA S will be operated within VLOS of the PIC and/or VO at all times.

24 The conditions and limitations detailed in this section are consistent with those set forth in the

previous FAA Section 333 grants for operations similar to those GE GR seeks to conduct through this petition

. See,

e.g

., supra note 4

.FAA Dockets

September 3 0 , 2015

Page 9

E. All operations will utilize a VO , who may be used to satisfy the VLOS requirement as long

as the PIC always maintains VLOS capability. The VO and PIC will be able to

communicate verbally at all times.

F. The grant of exemption and Manual s will be accessible during GE GR ’ s sUAS operations

and made available to FAA upon request. If a discrepancy exists between the conditions

and limitations in the grant of ex emption and the procedures outlined in the Manual s

, the conditions and limitations in the exemption take precedence and will be followed.

G. Prior to each operation, the PIC will inspect the s UAS to ensure it is in a condition for

safe flight. If the inspection reveals a condition that affects the safe operation of the

s UAS, it will not be operated until the necessary maintenance has been performed and

the s UAS is found to be in a condition for safe flight. The ground control station will also

be included in the preflight inspection. All maintenance and alterations will be

documented in the sUAS records.

H. Any s UAS that has undergone maintenance or alterations that affect its operation or

flight characteristics ( e.g

. , replacement of a flight cri tical component ) will undergo a

functional test flight prior to resumption of operations

. The PIC who conducts the

functional test flight will make an entry in the s UAS aircraft records of the flight.

I. GE GR will follow the manufacturer’s s UAS aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements.

J. The PIC will possess either an airline transport, commercial, private, recreational, or

sport pilot certificate, and a current FAA airman medical certifica te or a valid U.S.

driver’s license. The PIC will undergo at least 12 hours of training to ensure that he or

she can follow these procedures. The PIC will also meet the flight review requirements

specified in Section 61.56 in an aircraft in which the PIC is rated on his or her pilot

certificate.

K. Prior to conducting commercial operations under this exemption:

1. T he PIC will have accumulated and logged, in a manner consistent with Section

61.51(b)

, a minimum of : 12 hours of flying GE GR ’s sUAS or 24 flights accrued

bef ore being designated to operate it for commercial aerial data collection

. During training, proficiency, and experience

- building flights, the PIC will operate

the s UA S with appropriate distance from nonparticipants in accordance wi th

Section 91.119.FAA Dockets

September 3 0 , 2015

Page 10

2. A flight demonstration, administered by a GE GR

- approved and

- qualified pilot

,

will be successfully completed and documented. This documentation will be

available for review upon request by FAA

.

L. The s UA S will be operated at least 500 feet from all nonparticipating persons, vessels,

vehicles, or structures unless both of the following conditions are met :

1. Barriers or structures are present that sufficiently protect nonparticipating

persons in the event of an accident; and

2. The own er/controller of any vessels, vehicles or structures has granted

permission for operating closer to those objects and the PIC has made a safety

assessment of the risk of operating closer to those objects and determined that

it does not present an undue haz ard.

M. If the s UAS loses communications or loses its GPS signal, it will return to a

predetermined location within the security perimeter and land or be recovered in

accordance with the Manual s

.

N. The s UAS will abort the flight in the event of unpredicted ob stacles or emergencies in

accordance with the Manual s

.

O. The sUAS will not be operated unless it has enough available power to conduct the

intended operation and to operate after that for at least five minutes, or with the

reserve power recommended by the manufacturer, whichever is greater.

P. GE GR will obtain an Air Traffic Organization ( “ ATO ” ) issued Certificate of Waiver or

Authorization ( “ COA ” ) prior to conducting any operations above 200 f ee t AGL under the

exempt ion. 25

Q. All sUAS operated in accordance with this exemption will be identified by serial number,

registered in accordance with 14 C

. F

. R

. P art 47, and have identification (N

- Number)

markings in accordance with 14 C

. F

. R

. P art 45, Subpart C. Markings will be as large as

practicable.

25 Pursuant to its “blanket” COA, FAA will automatically grant a COA for flights at or below 200 feet

to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 pounds, operate during

daytime VFR conditions, operate within VLOS, and stay certain prescribed distances away from airports or

heliports. See FAA, FAA Streamlines UAS COAs for Se ction 333 (rev. Mar. 24, 2015),

https://www.faa.gov/news/updates/?newsId=82245 . This blanket COA allows flights anywhere in the country

except restricted airspace and certain other prohibited areas

, and FAA automatically issues it at the time the

exemption is approved. Id

. T o the extent GE GR plans to operate its sUAS above 200 ft. AGL, it will apply for a COA

authorizing it to do so.FAA Dockets

September 3 0 , 2015

Page 11

R. GE GR will follow the procedures established in the Manuals for documenting and

maintaining records of the s UAS maintenance, preventative maintenance, alterations,

status of replacement/overhaul component parts, and the total tim e in service of the

s UAS

.

S. Each s UAS operated under this exemption will comply with all manufacturer Safety

Bulletins.

T. The preflight inspection section described in the Manual s will account for all

discrepancies ( i.e

. , inoperable components, items, or equipment )

.

U. GE GR ’ s use of radio frequency spectrum for operation and control of the s UA S will

comply with the Federal Communications Commission ( “ FCC ” ) or other appropriate

government oversight agency requirements.

V. The documents required under Sections 9 1.9 and 91.203 will be available to the PIC at

the ground control station of the s UAS any time the aircraft are operating. These

documents will be made available to FAA or any law enforcement official upon request.

W. The s UA S will remain clear and yield the right of way to all other manned operations and

activities at all times (including, but not limited to, ultralight vehicles, parachute

activities, parasailing activities, hang gliders, etc.).

X. s UAS operations will not be conduct ed during night, as defined in Section 1.1. All

operations will be conducted under visual meteorological conditions ( “ VMC ” ). Flights

under special visual flight rules ( “ SVFR ” ) are not authorized.

Y. The s UAS will not be operated by the PIC from any moving d evice or vehicle.

Z. The s UA S will not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than three statute miles from the PIC.

AA. The s UA S will not be operate d within five nautical miles of an airport reference point

( “ ARP ” ) as denoted in the current FAA Airport/Facility Directory ( “ AFD ” ) or for airports

not denoted with an ARP, the center of the airport symbol as denoted on the current

FAA

- published aeronautical chart

, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to GE GR

. The letter of

agreement with the airport management will be made available to FAA and any law

enforcement official upon request.

BB. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will be reported to