1

Aetos Group Inc.

William Donberg

2065 5 Mile Rd

Traverse City, MI 49686

T: 1 231 409

- 5780

bdonberg@aetosgroup.com

August 19

, 2014

U.S. Department of Transportation

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Submission of Request s f or Determination u nder Section 333 of the FAA Modernization

and Reform Act and Exemptions Under 14 C.F.R. Section 11.81

Dear Sir or Madam:

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

Group Inc. (AGI) hereby requests a determination by the Secretary of Transportation authorizing

AGI to conduct commercial operation of its sUAS for the purposes of aerial inspection of

specific chemical plant infrastructure and environmental monitoring in the petrochemical

industry. Operations will be conducted within and under the safeguards outlined herein and as

may be established by the FAA under FM RA Section 333 (c).

AGI also petitions for exemptions as necessary to effect the determination requested pursuant

to FMRA Section 333. The attached documentation includes detailed exemption requests that

demonstrate how these exemptions are in the public interest and will maintain at least an equal

level of safety to existing regulations. Authorizing AGI to conduct inspections and

environmental monitoring of chemical plants would bring immediate and significant improvement

to environmental and operational risk management in the chemical industry. The AGI sUAS

would conduct inspections and monitoring in a manner that is significantly safer than current

practices.

The use of sUAS techno logy for chemical plant infrastructure inspections and environmental

monitoring will benefit the public interest in the following ways:

 Reduces the risk associated with elevated human operations

.3



## Table of Contents

Purpose 4

Aetos Group Inc. (AGI) Corporate Profile / Capabilities 4

Aeryon Aircraft Description s 6

Emergency Procedures and System Failures 9

EXHIBIT A

- Exemption / Waiver Requests 11

EXHIBIT B

- Proposed Limitations and Conditions 1 8

EXHIBIT C

- Summary of Aetos Group Inc. Section 333 Exemption Request 2 04



## Purpose

Aetos Group Inc. (AGI) is applying for an exemption from the listed Federal Aviation

Regulations ( “ FARs ” ) to allow for commercial operation of its sUAS to conduct aerial

inspection of specific chemical plant infrastructure and environmental monitoring in the

petrochemical industry. The operations described in this document will provide safety

enhancements, increase reliability of operations, and aid emergency response crews in

petroc hemical facilities. The sUAS will provide maintenance and reliability engineers

with high

- resolution imagery of infrastructure to include flare stacks, elevated pipelines,

tanks, and columns. The technology significantly reduces risk by eliminating the ne ed

for inspection personnel on elevated structures currently using rope access, scaffolding,

bucket trucks, and ladders. Improved efficiency allows the opportunity for higher

quality, more frequent inspections, and improvement of overall safety of the fac ility.



## Aetos Group Inc. (AGI) Corporate Profile / Capabilities

AGI is a leading consultant to sUAS manufacturers, operators, and the petrochemical

industry. We have provided insights that integrate emerging sUAS technology into

solutions that define alternatives to current methods of infrastructure inspections,

enviro nmental monitoring, and disaster relief. The management and staff of AGI include

a unique combination of significant experience in chemical plant operations, manned

aircraft operations and training, sUAS technology, and piloting experience.

All of the pr incipals of AGI hold commercial or ATP certificates with CFI ratings. We

have a background in professional aviation and military UAS operations with combined

manned flight experience of nearly 14,000 h ours and over 1,000 UAS combat flight

hours

, with many more in R&D and test flights.

For the last three years, in anticipation of eventual sUAS regulations, AGI has assisted

companies in the petrochemical industry in identifying high value applications of UAS

technology including infrastructure inspections, emergency response, air sampling

(fugitive emissions), environmental monitoring/compliance, and security.

AGI has aided in the design of proof of concept research projects with academia to

design and validate integrated UAS solutions that safely meet the needs of the

application.5

AGI ’ s principals have developed standard operating procedures for plant inspections

including:

• Risk analysis to include risk mitigation, risk management and risk assessments.

• Development of operational protocol s

.

• Interpreting FAA regulations and the impact they will have on future uses of UAS

technology in the petrochemical industry.

AGI has been actively involved with the ASTM F38 Committee assisting the FAA in

development of sUAS standards related to aircraft certification, pilot requirements and

operational protocol s

.



## Aeryon

Aeryon Labs Corporate Description

Aeryon Labs is a Canadian developer and manufacturer of unmanned aerial vehicles.

Founded in 2007, it is based in Waterloo, Ontario. The company is the world leader in

sUAS VTOL systems having gained significant experience with its systems in military,

commercial, and academic institutions around the world. Aeryon customers have

accrued thousands of hours of flight experience and parti cipated in the continuous

improvement of the aircraft and its systems and payloads. The wide customer base

includes military organizations in many countries

, including Special Operations Forces

in the US and Canada ; and leading Universities in the US and Canada

, including the

University of Alaska, Northwestern Michigan College, and Kansas State University.

Numerous law enforcement agencies in the US and Canada have accumulated

significant experience with Aeryon aircraft

, as have major global petrochemical

, oil and

gas

, and power companies. Together with its customers

, Aeryon has gained approvals

to fly in multiple countries around the world

, including Canada and the UK, as well as

Middle and Far Eastern countries. Aeryon aircraft have been approved for r esearch

purposes in multiple COAs through the US

, contributing to significant developments and

refinements in the aircraft.6

Aeryon Aircraft Description

The Scout and Sky Ranger are quad

- copter type vertical takeoff and land ing small UAS,

with four rotors mounted on booms and four legs

. Payloads are mounted underneath

the fuselage on a gimbal mount. Communications use common frequencies and are

digitally encrypted, which reduces the risk of hijacking and video interception.

Th e aircraft are controlled with a tablet based interface

, reducing pilot fatigue and

workload. The aircraft are piloted by the use of a stylus

, pointing to an area on a

moving map display. Altitude is controlled by using a slider bar on the touch screen

i nterface to command the aircraft to climb or descend.

The system is fully stabilized and GPS guided. Custom or commercially available map

data in several formats may be used for operator orientation. The aircraft can be flown

real

- time by the operator or pre

- programmed to fly a series of GPS waypoints. While

the aircraft is flying its pre

- programed flight path

, the operator always has full control of

the vehicle and can change its flight path or altitude immediately. Flight information

such as positio n, altitude, environmental conditions, signal link strength, GPS signal

strength, battery voltage, and other flight data is displayed to the operator in real time.

The aircraft itself is constantly monitoring environmental and system conditions and will

al ert the operator to any abnormalities. The aircraft ha ve many built in failsafe

mechanisms that will allow return to the point of origin and vertical land ing if an

emergency condition exists.

The aircraft and payloads are gyro stabilized

, allowing for exceptional imaging and

resolution quality at safe distances from infrastructure, which is essential for safe and

effective inspections. The aircraft have a quick

- change payload interface with common

interfaces including USB and Ethernet, which allows custom payloads to be developed.

The system is able to detect the type of payload connected, and configure it and

o perate it appropriately. The payload capaci ty of the system is 250 g (0.55 pounds ).

Offered payloads include gimbal

- mounted digital still and video cameras, a near IR

camera for remote sensing, a FLIR night

- vision camera, and a stabilized 10x Optical

Zoom camera.7

Aeryon Scout Technical Specificati ons

Deployment Vertical Take

- off and Landing

Operation Range 1 Mile

Operational Duration Up to 20 Minutes

Operational Velocity Up to 30 mph

Wind Limits Up to 30 mph (Gusts up to 50 mph)

Dimensions 31.5 in. x 31.5 in x 7.9 in

Max Weight 3.4 pounds

Power Source 11.1V Intelligent LiPo Battery

Aeryon Sky Ranger Technical Specifications

Deployment Vertical Take

- off and Landing

Operation Range 2 Miles

Operational Duration Up to 50 Minutes

Operational Velocity Up to 30 mph

Wind Limits Up to 40 mph (Gusts up to 55 mph)

Dimensions 40 in. x 40 in. x 9.3 in.

Max Weight 5.3 pounds

Power Source 1 4.8 V Intelligent LiPo Battery

Command and Control Systems

The Aeryon Ground Control Station allows the operator simultaneous control over

aircraft and payloads. The touch screen control allows for quick navigation and data

entry while the display screen provides all essential flight data to the operator.

Telemet ry data is transmitted to the command station at least once per second.

Displayed on GCS:

• Position

• Navigation Route

• Altitude

• Heading

• Battery voltage and time remaining

• GPS signal strength

• Radio link strength8

• Aircraft status to include error messages or failures

• Date/time

• Sensor position and orientation relative to s UAS

On

- board Flight Instruments

– The s UA S is equipped with an Inertial Navigation

System (3

- axis gyroscope, magnetometer, GPS receiver, and static pressure sensor)

and a sonar sensor for pr ecision AGL altitude measurement.

On

– board computer systems

– The s UAS is equipped with on

- board computer

systems to monitor (sensors, battery, etc.), control (speeds, altitude, position, etc.), and

communicate (control, telemetry, etc.).

On

- board guid ance and navigation equipment

– The s UAS can operate

autonomously; it does not require any input from ground

- based equipment, or from the

pilot to hover in place.

Frequency Allocations

– 900 MHz and 2.4 GHz

.

Fly away protection

– T o prevent a “fly away” or other potentially dangerous situations

,

the aircraft employs a system of fail

- safes that will either return the aircraft to its home

origin point or land the aircraft in its present position. See “E mergency P rocedures and

S ystem F ailures ” in section 3 for additional detail

.

Takeoff and Landing

– The sUAS has vertical lift autonomous launch and recovery. A

Landing Zone ( “LZ” ) is designated by the operators and identified in the GCS software.

For launch procedures the aircraft will take off and hover 3 meters directly above the LZ

and hold until further operator instruction is given. The aircraft will automatically adjust

for wind during this period.

Navigation System

– Specific maps

, such as air sectional and geographic maps, can

be downloaded to the display screen and overlaid with GPS positional data. Waypoints

can be created before and during flight operation creating specific locations and

sequences for the aircraft.

Redundant Systems

– The s UAS combines the input from a multitude of sensors.

Even though the data from all sensors is required for optimal system performance, a

single sensor malfunction is likely to result in degraded performance rather than leading

to a catastrophic failure.9



## Emergency Procedures and Syst em Failures

Engineered Failsafe Mechanisms

Lost Communications

The sUAS does not need constant signal from the tablet to continue flying.

Communication outages are detected by the system and are reported to the pilot.

During the communication outage th e aircraft will hover in place, climb to a pre

- set safe

altitude, and then fly to its takeoff location. If communication is still not established the

aircraft will descend slowly and make a landing at the point of takeoff. All of this is

accomplished with out input f ro m the operator.

If the aircraft receives interference or another overpowering signal

, the system will

simply go into its lost communication procedure as stated above. It will climb to a safe

altitude, fly home and land.

Communications Data Security

All communication links are encrypted. The communication system and protocol is

designed in such a way that control of the aircraft cannot be taken over by accident. The

video feed is also encrypted. Any unauthorized person attempting to receiv e the video

would see a scrambled picture.

Battery Life

The battery voltage and flight time remaining are displayed to the operator throughout

the flight. When 3 minutes of flight time is remaining

, a warning is given to the operator.

If the operator does not bring the aircraft home, the system will return home (takeoff

point at a safe transit altitude) on its own. The sUAS is equipped with an intelligent

battery monitoring system that will allow i t to leave its present position and fly home with

reserve battery power to make a safe landing under current environmental conditions.10

Ignition Source Resistant

The aircraft are equipped with a sealed LiPo battery pack and is operated by 4

brushless elec tric motors. The brushless motors, by their design, do not spark or arc

while being operated. The operating temperature of the motors and the battery is

extremely low.

Potential Component Failures

The aircraft have highly engineered systems monitoring software. Examples include

battery health and temperature, voltage going to the motors, GPS accuracy, magnetic

anomalies, vibration sensing, and yaw detection. There is a warning prior to any major

failure, giving time to safely manage the situation. If the failure is considered “ non

- fatal

, ”

it will return home and land. If it is considered “ fatal

, ” it will set down immediately at its

present position. Automatic pre

- flight checks prevent the UA S from taking off if pr oblem

conditions are present.

Defined “ No Fly Zones ”

The na vigation software allows for preplanning No Fly Zones which can allow the

operator to maintain clearance from any “prohibited areas

. ” The Scout and Sky Ranger

will operate with geo

- fencing. This technology allows the operator to effectively put a

GPS based perimeter around the area of operations which will keep the aircraft in a

designated “operational box” regardless of normal or emergency operations. The geo

fence is custom designed and ca n be adjusted based on each location of operation.

Visual Line

- of

- Sight Loss

All flight operations will be conducted with the s UAS within visual sight of the pilot. If for

some reason the pilot ’ s view becomes obstructed and line

- of

- sight is lost, the a ircraft

will hover in position until line

- of

- sight is reestablished.11



## EXHIBIT A

- Exemption / Waiver Requests

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 47.3(b)(2);

14 C.F.R. 47 .31(c);

14 C.F.R. 61.133(a)(1)(ii);

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a) & (b). 1

The following discusses each rule listed above and explains why exemptions pursuant

to the proposal set forth in this letter are appropriate, provide an equivalent level of

safety, and are in the public interest.

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS

UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

Aetos Group Inc. requests an exemption from the following regulations

, as well as from

any additional regulations that may be necessary to effect the Secretary’s determinatio n

under FMRA Section 333.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. § 91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthiness certificates as requir ed by FAR § 91.203 (a) (1). Given

1 Exemptions from the requirements of sections 91.9(b), 91.203(a) and (b), 47.3(b)(2), and 47.31(c) of Title 14

C.F.R. are sought only in an abundance of caution, as they appear to be unnecessary given a recent FAA

Interpretation. Memorandum from Mark Bury, FAA Assistant Chie f Counsel for International Law, Legislation and

Regulations, to John Duncan, Director, FAA Flight Standards Service (Aug. 8, 2014), available at

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/

2014/duncan

- afs

- 1

- 2%20

- %20(2014)%20legal%20interpretation.pd f

.12

the size and limited operating area associated with the aircraft to be utilized by the AGI,

an exemption from Part 21 Subpart H meets the requirements of an equivalent level of

safety under Part 11 and FMRA Section 333. The Federal Aviation Act (49 U .S.C. §

44701 (f)) and FMRA Section 333 authorize the FAA to exempt aircraft from the

requirement for an airworthiness certificate, upon consideration of the size, weight,

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

particular UAS. In all cases

, an analysis of these criteria demonstrates that the s UAS

operated without an airworthiness certificate, in the restricted environment and under

the conditions proposed will be at least as safe, or safer, than a conventional aircraft

(fixed wing or rotorc raft) operating with an airworthiness certificate without the proposed

restrictions and conditions.

The sUAS to be operated hereunder is less than 7 pounds, fully loaded, carries neither

a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and

operates exclusively within a secured area. Operations under this exemption will be

tightly controlled and monitored by the operator under AGI’s safeguards and in

c ompliance with local public and facility safety requirements. AGI will co ordinate with

the FAA as necessary to obtain airspace waivers and to support the issuance of

NOT AMs. Receipt of the prior permission of the land owner, the size of the aircraft, the

lack of flammable fuel, and the fact that the aircraft is carried to the l ocation and not

flown there all establish the equivalent level of safety. This provides at least an

equivalent level of safety to that of operations conducted with conventional aircraft that

would be orders

- of

- magnitude larger and would be carrying passen gers, cargo, and

flammable fuel.

14 C.F.R. § 45.23 (b) : Marking of the Aircraft.

The regulation provides:

When marks include only the Roman capital letter "N" and the registration

number is displayed on limited, restricted or light

- sport category airc raft or

experimental or provisionally certificated aircraft, the operator must also

display on that aircraft near each entrance to the cabin, cockpit, or pilot

station, in letters not less than 2 inches nor more than 6 inches high, the

words "limited," "re stricted," "light

- sport," "experimental," or "provisional,"

as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be

needed as the s UAS will have no entrance to the cabin, cockpit or pilot station on which13

the word “ Experimental” (or other marking as required by the FAA) can be placed.

Given the size of the sUAV, two

- inch lettering will be impossible. The word

“Experimental” (if required) will be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its

fuselage as required by § 45.29 (f) in such a manner that the pilot, observer and others

working with the sUAV will see the identification. The FAA has issued the following

ex emptions to this regulation as Exemptions Nos. 10700, 8738, 10167 and 10167A

.

14 C.F.R. §§ 47.3(b)(2) and 47.31(c): Carriage of R egistration.

These regulations require that an applicant for aircraft registration carry “in the aircraft”

the second copy of the registration application as temporary authority to operate without

registration.

Given the size and configuration of this sUAS, there is no room to carry the document

aboard the aircraft. Maintaining this document at the pilot’s control station would meet

the intent of the rule and establish an equivalent of safety.

14 C.F.R. § 61.1 33 (a)(1)(ii) : Commercial P ilot P rivileges and L imitations.

The regulation provides:

A person who holds a commercial pilot certificate may act as pilot in

command of an aircraft for compensation or hire, provided the person is

qualified in accordance wi th this part and with the applicable parts of this

chapter that apply to the operation.

The FAA requires a commercial pilot certificate for operations for compensation or hire

and AGI supports this. However, the commercial certificate is category and clas s

specific. Because the FAA has not formally assigned a category or class to UAS

, we

request an exemption to all category and class requirements of the commercial pilot

certificate within the scope of this exemption. AGI will require all of its UAS operators to

hold a commercial pilot certificate of any category or class.

14 C.F.R. § 91.7(a): Civil A ircraft A irworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in

airworthy condition. As there will be no ai rworthiness certificate issued for the aircraft,14

should this exemption be granted, no FAA regulatory standard will exist for determining

airworthiness. A ll maintenance conducted on the aircraft will be accomplished

according to the manufacturer ’s maintena nce and operating procedures. Operators will

strictly adhere to operating checklists and procedures for the aircraft in accordance with

AGI ’s Operations Manual

. All operators will be commercially rated and have proper

training for the aircraft. G iven th e weight, speed, operational capability, and controlled

flight environment of the s UAS

, it will remain in a condition of airworthiness at an

equivalent level of safety

.

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

The regulation provides:

No person may operate a U.S.

- registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by

§ 21.5 of this chapter, unless there i s available in the aircraft a current

approved airplane or Rot or craft Flight Manual, approved manual material,

markings, and placards, or any combination thereof.

Given the size and configuration of the sUAS

, there is no room or capacity to carry a

flight manual on the aircraft.

The equivalent level of safety wil l be achieved by keeping the flight manual at the

ground control station where the pilot flying the sUAS will have immediate access to it.

The FAA has issued to Trimble and others the following exemptions to this regulation:

Exemption Nos. 8607, 8737, 8738

, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602,

32827, and 10700.

14 C.F.R. § 91.119: Minimum S afe A ltitudes

.

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

(d) allows helicopters to be operated at less than the minimums prescribed, provided

the person operating the helicopter complies with any route or altitudes prescrib ed for

helicopters by the FAA. As this exemption is for sUAS that are multi

- rotor VTOL that

can be considered helicopters and the exemption requests authority to operate at

altitudes up to 400 AGL, or not more than 100 above an object to be inspected, an

exemption may be needed to allow such operations. As set forth herein, the s UAS will

never operate at higher than 400 AGL. It will

, however

, be operated in a restricted area15

where buildings and people will not be exposed to operations without their pre

- obtained

consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the

sUAS

, as well as the location where it is operated. No flight will be conducted without

the permission of the property owner. Advance notice t o the property owner and a Safe

Work Permit will be issued ensuring all affected individuals will be aware of planned

flight operations. Compared to flight operations with aircraft or rotorcraft weighting far

more than the maximum 7 pounds proposed herein and the lack of flammable fuel, any

risk associated with these operations is far less than those presently presented with

conventional aircraft operating at or below 500 AGL. In addition, the low

- altitude

operations of the sUAS will ensure separation bet ween these sUAS operations and the

operations of conventional aircraft that must comply with Section 91.119.

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

.

This regulation 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 setting available before departure. ” As the sUAS may not have a

barometric altimeter, but instead GPS altitude control, an exemption may be needed.

An equiv alent level of safety will be achieved by the operator as the sUAS uses AGL

height from its initialization (launch) point, cross

- referenced with MSL altitude of the

launch point.

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

.

Sec tion 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 minutes; or (2) At night, to fly

after that for at least 45 minutes. ”

The battery powering the sUAS provides approximately 20 minutes of powered flight,

which is less than the required reserve for a VFR day flight. AGI believes that an

exemption from 14 CFR § 91.151(a) falls within the scope of prior exemptions. See

Exemption 10673 (allowing Lockheed M artin Corporation to operate without compliance

with FAR 91.151 (a)). Operating the s U AS, in a tightly controlled area where only

people and property owners or official representatives who are made aware of the

operation will be allowed, with less than 30 minutes of reserve fuel, does not engender16

the type of risks that Section 91.151(a) was intended to alleviate given the size and

speed of the small UAS. Additionally, without exemption from 91.151(a)

, the sUAS

would not be able to launch for any flight.

AGI believes that an equivalent level of safety can be achieved by first implementing

operational limitations on flight times. The battery capacity will be monitored in flight

and the flight will be terminated when 25% of the battery capacity is remaini ng. This

restriction will be more than adequate to return the aircraft to its planned landing zone

from anywhere in its limited operating area. The second level of safety is achieved

through the use of an aircraft battery monitoring system. The aircraft system will alert

the operator of low battery voltage and return the aircraft to its take off location before

battery capacity is depleted.

Similar exemptions have been granted to other operations, including Exemptions

2689F, 5745, 10673, and 10808.

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

.

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft

unless it has within it the following:

(1) An ap propriate and current airworthiness certificate.

. . . (b) No person may operate a civil aircraft unless the airworthiness

certificate required by paragraph (a) of this section or a special flight

authorization issued under § 91.715 is displayed at the cab in or cockpit

entrance so that it is legible to passengers or crew.

The sUAS fully loaded weighs no more than 7 pounds and is operated without an

onboard pilot. As such, there is no ability or place to carry certification and registration

documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot flying the sUAS will have immediate access to them, to the

extent they are applicable to the sUAS. The FAA has issued numerous exemptions to

this regulation. A representative sample of other exceptions includes Exemption Nos.

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.17

14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance

Inspections

.

These regulations 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 provided in paragraph (c) of this section, have discrepancies repaired as

prescribed in part 43 of this chapter..., ” and others shall inspect or maintain the aircraft

in compliance with Part 43.

Because these regul ations and Part 43 apply only to aircraft with an airworthiness

certificate, the y will not apply to the sUAS

. Maintenance will be accomplished by

properly certified and trained operators according to manufacturer ’s published

maintenance procedures

, follow ing the developed checklist and operating procedures

for the aircraft. An equivalent level of safety will be achieved because these sUAS are

very limited in size

, carry a small payload

, and operate only in restricted areas for

limited periods of time at a n altitude not to exceed 400 feet AGL. If mechanical issues

arise

, the s UAS can land immediately and safely

. As provided in the c hecklist, the

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

required maintenance, and keep a log of any maintenance performed. The operator is

the person most familiar with the aircraft and best suited to maintain the aircraft in an

airworthy condition to provide the equivalent level of safety. Moreover, neither sUAS

will allow fligh t if anomalies are detected.18



## EXHIBIT B

- Proposed Limitations and Conditions

These limitations and conditions to which AGI agrees to be bound when conducting

commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 7 pounds.

2. The sUAS will go through a Failure Mode and Element Analysis (FMEA) to

ensure the highest level of safety.

3. The Pilot will use a detailed checklist for every flight.

4. Flights will be operated within line of sight of the pilot during daylight hours.

5. Flights will be terminated no later than manufacturer designed return

- home

battery voltage or 25% remaining battery capacity.

6. Flights will be operated at an altitude 400 feet AGL or lower.

7. Minimum crew for each operation will consist of the sUAS Pilot and the Visual

Observer.

8. The sUAS pilot will be an FAA licensed airman with at least a commercial pilot’s

certificate and second class medical.

9. The sUAS p ilot (operator) will be Pilot in Command (PIC).

10. The sUAS will only operate within the lateral boundaries of customer property.

Confined “ Safe Zones ” will be established for each flight. These zones will be

free of unnecessary hazards or risks and non

- participating personnel. The Scout

and Sky Ranger will operate with g eo

- fencing that will confine the aircra ft to a

pre

- defined “operational box.”

11. A briefing will be conducted and a work permit will be issued by the customer

prior to each sUAS operation. Work permits will be issued only if customer and

PIC determines sUAS operation is safe in the vicinity. This also gives

permission to operate over the private, controlled

- access property.

12. AGI will coordinate with the appropriate ATC facility or Flight Standards District

Office in order to obtain airspace waivers and effect issuance of NOTAMs, as

necessary.

13. Pilot s will have been appropriately trained by the sUAS manufacturer or other

authorized instructor, and current on its operation prior to flight. Observer s will

have been trained in operation of sUAS generally.

14. The p ilot and o bserver will have current s pecific safety training for the area in

which sUAS operations will take place.

15. The pilot and o bserver will at all times be able to communicate by voice.

16. If the sUAS loses command/control communications (C2) or loses its GPS

solution, the UAS will have capa bility to return to a pre

- determined location within

the Safe Zone and land.19

17. The sUAS will have the capability to abort a flight in case of unpredicted

obstacles, emergencies, or system anomalies.20



## EXHIBIT C

- Summary of Aetos Group Inc. Section 333

Exemp tion Request

Docket Number: FAA

- 2014

- XXXX

Petitioner: AETOS GROUP INC.

Section s of 14 C.F.R. Part 21;

1 4 C.F.R. 45.23(b);

14 C.F.R. 47.3(b)(2);

14 C.F.R. 47.31(c);

1 4 C.F.R. 61.133(a)(1)(ii);

14 C.F.R. 91.7(a);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2); and

1 4 C.F.R. 91.417(a) & (b).

Description of relief sought: The petitioner seeks exemptions in order to commercially

operate its small UAS for aerial inspection of plant infrastructure and environmental

monitoring in the petrochemical industry.