July 3, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Section 333 of the FAA Reform Act of 2012 Dear Administrator, I, Calvin C. Stallings , d.b.a. SkyVision Aerial Solutions, herein referred to as (the petitioner), am writing to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that the petitioner, Calvin C. Stallings , an owner and operator of a small unmanned aircraft system (sU AS), petition for exemption from the Federal Aviation Regulations listed below and any regulation as required by the FAA that is deemed necessary in order to conduct commercial UAS operations as described. The requested exemption would permit the petition er to pursue, safe, professional, for profit services to private and public entities within the State of Alabama and adjoining states utilizing a small unmanned aircraft system (sUAS) for aerial still and video data capture for, but not limited to the foll owing purpose:

- Real Estate Sales

- Property Video Survey

- Residential/Commercial Roof inspections

- Crop Inspection

- Photo/Videography of rural contracted outdoor recreational activities on private and public use lands (Prior Permission and coordination o nly )

- Fire Survey and Rural Search assist to local public and private entities. As described herein, the petitioner will use an operator with a certified and current, Private Pilot with a class 3 medical or better . The petitioner has over 2 years of aviat ion experience within the industry. The petitioner has been flying within the State of A labama for over 2 years and is experienced and familiar with the standard operating practices and procedures, as well as safety attitudes and safety requirements within the aviation industry. The petitioner is familiar with the C.F.R. and FAR, all classes of Airspace and standard operating practices and proced ures within the State of Alabama , with extensive knowledge of Central Alabama’s geography and trends of weather i n all seasons. The initial (sUAS) to be utilized during the operations is a consumer class helicopter, quad

- rotor aircraft. It is manufactured by Yuneec, Inc. and has the manufactures model designation Q500 + Typhoon. It is an advanced (sUAS) with state of the art safety features, GPS lock, altitude, position hold stabilization, smart mode, angle mode follow me and return to home mode. The ground station has telemetry with altitude, groundspeed, GPS location and battery life for both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. Aircraft LED visual alert indicators for low battery, GPS loss, and communication loss. The UAS has a first person view on the controller that **is not to be used**  for flight by the PIC . The UAS has the ability to link with a smartphone or tablet for video link separate from the onboard display if needed. The UAS has separate radio frequencies for telemetry and video downlink and aircraft control. See the following manufactures specifica tions.Yu **neec Q500 +**  **Typhoon, quad copter**

**Flight Time** Up to 25 Minutes **Dimension** 16.5x16.5x9.5in (420x420x240mm) **Diagonal Length Without Rotor Blades** 22.2in (565mm) **Propeller/Main Rotor Diameter** 13.0in (330mm) **Weight Without Battery and Payload** 40.0oz (1130g) **Battery** 5400mAh 3S 11.1V LiPo (included) **Charger** 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) **Transmitter** 10

- channel 2.4GHz with 5.8GHz video downlink (included) **3 Flight Modes** Smart, Angle and Home Modes **Maximum F lying Height**  Default 122m (400ft) Above Ground Level (Adjustable via the Q500 GUI) **Maximum Rotation Rate** 65°/s **Maximum Roll Angle** 35° Operating Temperature Range

- 5 °C to 80 °C

**Ca mera Gimbal System**  **Dimension** 4.5x1.4x2.9in (115x135x74mm) **Weight** 6.5oz (185g) **Focusing System** Aerial Optimized Fixed Focus **Field of View** 130° **Video Transmission Range** FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) with ST10 **Video Resolution** FULL HD 1080p

- Adjustable 60, 50 or 48 FPS **Photo Re solution**  16 Megapixels **Storage (memory)** microSD Class 10, 4 to 128GB **Control Angle Accuracy** ±0.02° **White Balance** Automatic White Balance **Transmission Band** 5.8GHz **Input/Operating Voltage** 7.0V to 14.0V DC **Working Temperature** 0°C

- 50°C **Storage Temperature**

- 20 °C to 60 °C **Angular Vibration Range** ±0.02° **Control Range** Pitch : between

-90° and 0° Yaw : between 0° and 360°
**Personal Ground Station Operating System**  AndroidTM **Number of Channels** 10 **Control Transmission Distance/Range (Optimum Conditions)** FCC Compl iance: Up t o 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) **Robust Radio Control Modulation** Yuneec Protocol **Video link Frequency Band** 5.8GHz **Video Transmission Distance/Range (Optimum Conditions)** FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) **Flight Systems Telemetry Data On Screen Display (OSD)** Yes**LED Backlit LCD Screen** Capacitive Multi

-Touch 5.5”

**Tactile (Vibrating) and Audible Feedback** Yes **Built**

**- In LiPo Battery Voltage / Capacity**  3.6V/5200mAh 18.72W h **Charger** Auto

- Charge Mode via Micro

- B USB Cable with AC to 5V DC USB Power Supply (Included) UAS are often seen as superior to manned helicopters due to the smaller size and lower costs, reduced noise and as such, a much smaller environmental and safety impact. The petitioner requests exemption to operate a Yuneec, Q500 + Typhoon equipped with a three

- axis CGO2 Gimbal and Camera, both products of Yuneec. This sUAS has a pre

- programmed limit for the altitude above ground level at 400 feet and a Geo fenc e while in Smart Mode with a distance limit of 300 feet from the controller. These limits are preset at the factory and will be kept at those limits, which currently comply with the AMA’s and FAA requirement for Visual Line of Sight limitation and an AGL l imitation. The ground station is also programmed with a safety feature that disables motor start up if within Class B, and C airspace boundaries. The Q500 + also has the failsafe

- automated feature of return to home in the event that communication is lost be tween the ground station and the aircraft. In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The petitioner will

-- a. Only operate its UAS in direct visual line of sight of the pilot and observer without use of a visual aid other than corrective lenses. b. Operate at an altitude no greater than 400 feet above the ground. c. Operate with due vigilance and known practi ced see and avoid scanning techniques to avoid any conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UAS flight will be immediately terminated if a potential conflict may exist. d. Operate over private or public sites only with prior permission from property owner or owner’s agent or legal authorities as allowed by law. e. Terminate flight when any unsafe condition exists. f. Terminate flight when battery voltage drops to 30% of battery capacity or when the 1 st low ba ttery alert occurs per the Q500 + Typhoon Instruction Manual, not to exceed 18 minutes run time. g. Operate at a ground speed of 0 to 15 mph during on site missions. h. Operate in accordance with the guidance and standards set forth by the AMA, the UAS ma nufacturer and the administrator. i. Operate with a minimum crew for each operation consisting of the PIC and a visual observer in direct communication utilizing appropriate verbal, radio or cell phone as needed. j. Insure the sUAS operator on the contro ls will be at least a current Private Pilot with a class III medical. k. Provide ground instruction with standards and content currently accepted by the administrator for private pilot knowledge testing, to the observer and or UAS. **The petitioner reques ts exemption from 14 CFR part 61.113 Private Pilot Privileges, Pilot in Command**  **Section (a).** T he petitioner may elect to utilize certified private pilots with class III medicals to conduct operations with the sUAS. In the Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the ground. The petitioner requests the same consideration and limitations as previously granted.**Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness.** As no Airworthiness Certificate is available for this

sUAS the petitioner requests exemption under this part utilizing a preflight inspection an d the manufacturers documents for determining compliance of the sUAS airworthiness. The petitioner warrants compliance to part 91.7(b) in that the operation will only be conducted after a thorough preflight and pre

- mission planning inspection is completed, to include current and forecast weather, airspace, notams, area of operations, and notice issued to non

- participating persons in local proximity. The petitioner will utilize the Yuneec, Q500 + Instruction manual, quick start guide and the petitioners own p re -flight checklist included in the attached supplements to determine the sUAS airworthiness. **The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes.** The petitioner requests exemption from Section (c) with the following cond itions and limitations. The petitioner requests the exemption due to the scope of the operations to be performed and the requirement to operate below 400 feet AGL. The Petitioners primary mission would be to record data or survey of persons, property or st ructures as listed above. The sUAS size, weight, speed and limited operating times and area, as well as the soft materials used in the construction of the sUAS, would provide an equivalent or greater level of safety as intended under this part.
The Q500 + is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. The sUAS has a vertical to near vertical descent in the event of a power failure. Fly

- a -ways would be the greatest or most dangerous risk to non

- participating persons. The Q500 + h as no documented (fly

- away), while operated under GPS lock within the parameters of the Q500 + operating instructions. The Q500 + is a very stable, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized UAS. In an emergency the sUAS would be quickly brought down per the loss of control procedure as described in the emergency procedures checklist, adequate time to complete the procedure would exist due to the 0 to 15 mph operational groundspeed of the Q500 + . The risk to persons 100 feet away would be at no greater risk than persons located 500 feet away. The petitioner requests exemption from the 500

-foot altitude restriction and the 500

-foot stand off restriction from persons, property or vessel applied to previous grants of exemptions. The exemption is requested with the following conditions and limitations in condu cting the petitioners operation

— a. The sUAS will be operated at an altitude of no more than 400 feet above ground level. b. The sUAS will not be operated at greater than a 400

-foot slant distance from the PIC. c. The sUAS will not be operated over any non

- participating person. d. The sUAS will not be operated over a non

- participating property, structure or vessel without prior permission from the property owner or legal representative. e. The sUAS will maintain a minimum slant distance of 100 feet from any non

- participating person and wil l increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time will the sUAS be operated closer than a 100

-foot slant distance to a non

- participating person unless that person is behind a protective barrier or shielded from possible de bris in the event of a crash. f. A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled operation in an urban business or residential area within 500 feet of the operation, informing of the time, location and safety hazards to persons or property, the notice will include a phone number to voice objections or concerns. g. Warning signs will be displayed on the perimeter of the safety zone to alert passers

- by of the hazard and warning to stay back and behind cover. If the safety zone is breeched, flight will be immediately terminated. h. The sUAS will be operated over public rural lands with the same stand off distance and altitude restrictions afforded persons, property and vessels per e. above.**The petitioner reques ts exemption from 14 CFR Part 91.121, Altimeter settings.**  The UAS will not have

a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within VLOS and at or below 400 feet AGL, combined with the petitioner’s intention to limit the altitude of the UAS through flight limit function on the UAS, has been previously ruled to be a sufficient method for ensuring the UAS operations do not adversely affect safety. The altitude information will be generated by GPS equipment inst alled onboard the aircraft, and/or a static pressure sensor (barometer), which aids in estimating the altitude. **The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR conditions,**  prior relief has been granted for m anned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS

- specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) condit ions. The petitioner’s UAS provides low battery warnings that indicate the PIC must command the UA’s return to the launch point when low battery capacity voltage is reached. The UAS also provides 2 and 3 rd increased intensity critical low battery warnings through audio and vibration indicating that the UA must be landed immediately, additionally a fail safe automatic landing will occur when the battery is at absolute critical low voltage. The petitioner warrants that the sUAS will be landed immediately upon the 1 st low battery alert or no longer than 18 minutes which ever occurs first. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landi ng point and land the UA with 30% battery power remaining.
**The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401**

**- 417),) Maintenance required,**  **91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration,** 5 **91.409 (a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records** 

. Currently the manufacturers maintenance procedures govern preflight with no limits other than on

- condition. The petitioner will complete all authorized component replacements at the pet itioner’s base of operations or in the field as required. The manufacturer or authorized repair center will complete any maintenance or repairs that cannot be completed by the petitioner. The petitioner warrants that preflight, post flight and maintenance procedures set forth in the petitioner’s supplements attached should provide an acceptable level of safety for the operations performed and is consistent with those of previous grants. In addition the petitioner will comply with any and all manufacturers u pdates for UAS and Ground station as well as any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be kept with the sUAS ground station and base of operations as required, (See Supplement). As previously stated the pet itioner has demonstrated over 2 years of safe operations in aviation . The petitioner requests the administ rator to consider that the same standards and safe practices utilized by this petitioner would be an asset and greatly benefit the development and integratio n of the UA system into the National Airspace. Furthermore it is of this petitioner’s best interest to insure safe, compliant and professional commercial operations for the furtherance of public safety in the aviation industry. Sincerely, Calvin Croy Stall ings , 90 Glory Ln Cropwell, AL 35054 (205)

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