July

22 , 2015 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room w12 - 140 1200 New Jersey

Avenue, SE Washington, DC 20590 Subj ect : Petition for Exemption to Operate a Yuneec Q
- 550 Pro Quad
- Copter Unmanned Aerial System for Aerial Video ofAreas Showing Degradation/ Reclamation/

Restoration/Landscaping/Hardscaping Dear Sir or Madam: The purpose of this letter is to petition the Federal Aviation Administration for an exemption from certain Federal Aviation Regulations in order for the petitioner, Vicki Felmlee , to operate an Unmanned Aerial S ystem (UAS) . Ms. Felmlee is well acquainted with the risks that come with the privilege of operating an aircraft in the United States, but is also familiar with the opportunities available via new unmanned flight technology . She has flown radio - controlled model aircraft recreationally and has designed flight simulator control panels for private aircraft manufacturers. She also has more than f orty hours of flight time with the Yuneec Q - 550 Pro that is the subject of this Petition. The petitioner desires to use the Yuneec Q - 550 Pro to record low altitude video of areas showing degradation/ reclamation/restoration/landscaping/hardscaping . Pursuant to 14 CFR §§ 11.61 - .103 and Section 333 of the FAA Modernization and Reform Act of 2012, PL112 - 95 (Feb. 14, 2012), the petitioner is submitting the following information with this request: 

### Identity of Petitioner. Petitioner: Vicki Felmlee 178 G lory View Drive Grand Junction CO 81503 info@tcsmg.com 970 - 245 - 8484

### Description of Operations. **A. The UAS that is the Subject of this Petition.** Ms. Felmlee is the owner of a Yuneec Q - 550 Pro Quadcopter with a 3 - axis gimbal and HD video camera, serial number of PH645419244, and its associated portable ground station controller (together the "Subject UAS"). The Subject UAS is a quad - copter with a camera mounted beneath it, piloted via a portable ground st ation. It weighs less than 3 pounds . Sh e purchased the Subject UAS on November 30, 2014, from Hobb y Hut in Grand Junction, Colorado . The Yuneec Q - 550 Pro is a widel y known unmanned aircraft with a full range of GPS featurs . The portable ground station used by Ms. Felmlee to pilot the unmanned aircraft is a wireless communication device using an FCC - compliant 5.8GHz frequency band for controlling the aircraft, and a 2.4 MHz data link for video and flight data. The Subject UAS is equipped with lost - link capability , which enables the Yuneec Q - 550 Pro to enter a fail - safe Return - to - Home Mode in the event that the link between the aircraft and the ground station is lost. The Subject UAS can operat e for a total of approximately 25 minutes on one battery charge. It has a maximum rang e from the ground station of 2,6 00 feet. However, it also has clear height and radius reading s to establish an operations area ; it has a default he ight limit of 4 00 feet AGL. **(Please see Chart 1 -**  **Genera l Specifications of the**  **Yuneec Q -**  **550 Pro )**  

### B. The UAS Pilot in Command. Ms. Felmlee has owned and operated her own business, The Caret Shoppe, Inc., since 1996. She holds a degree in geology and has worked with many governmental agencies and NGOs (non - governmental organizations) on various projects from Environmental Protection Agency documents to field operations for environmental survey s. Doing business as TCS Marketing Group, Inc., she has also helped many NGOs with establishing strategies, documenting research, and providing Scopes of Work and grant writing. Active in her community, she has held numerous positions with non -profit and city /county boards and n eighborhood planning committees; she is currently the Colorado Director - designate for the Old Spanish Trail Association (to b e confirmed in September, 2015). She is a member of the Academy of Model Aeronautics. Ms. Felmlee asserts that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however, s he can achieve an equivalent level of safety as achieved by current regulations because her UAS does not carry any pilots or passengers. Further, a pilot license may not ensure re mote control piloting skills. Sh e further indicates that the risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus s he requests an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot in Command.Regarding UAS operational training, Ms. Felmlee has flown numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of her UAS’ performance under different temperature and weather conditions as well as operating the camera settings in safe environments. She also practices computerized simulated flights to maintain adequate skills and response reflex time. Ms. Felmlee will maintain a log of all operations with maps showing locations of areas **(Figures 1 and 2**
**– Example**  **s of Log and Map**  **).** Ms. Felmlee agrees to abide by the UAS Operating Parameters listed in the next section 

### UAS Operating Param **eters .**  Ms. Felmlee states s he will abide , at a minimum, by the following additional operating conditions under the exemption for which s he is making application:

• Operate her UAS below 300 feet and within a radius of 1,000 feet from the controller to aid in direct line of sight visual observation; • Operate the UAS for 15 - 20 minutes or less, per flight • Land her UAS prior to the manufacturer’s recommended minimum level of battery power; • Operate the UAS onl y within visual line of sight (VLOS), and during hours of daylight; • Utiliz e the UAS’ global positioning system (GPS) flight safety feature whereb y it hovers and then slowly lands if communication with the remote control pilot is lost; • Conduct all operations under her own personal and flight safety protocols contained in the operating documents and will activel y anal yz e flight data and other sources of information to c onstantly update and enhance her safety protocols; • Contact respective airports if operations will be within 5 miles to advise them of her estimated flight time, flight duration, elevation of flight, and other pertinent information; • Always obtain all necessary permissions prior to operation; and • Have procedures in place to abort flights in the event of safety breaches or potential danger.

### Specific Sections of 14 CFR From **Which Petit ioner Seeks an Exem** 

**ption** Ms. Felmlee seeks an exemption from the following FARs: 14 CFR Part 21, Subpart H Certification procedures for products and parts, Airworthiness Certificates 14 CFR Part 36 Noise standards: Ty pe and airworthiness 14 CFR § 45.23 Display

of marks; general 14 CFR Part 61 Certification: Pilots, flight instructors, and ground instructors 14 CFR § 91.7 Civil aircraft airworthiness 14 CFR § 91.9 Civil aircraft flight manual, marking, and placard requirements 14 CFR § 91.103 Preflight ac tion 14 CFR § 91.105 Flight crewmember stations 14 CFR § 91.109 Flight instruction 14 CFR § 91.119 Minimum safe altitudes 14 CFR § 91.121 Altimeter settings 14 CFR § 91.151 Fuel requirements for flights in VFR conditions 14 CFR § 91.173 ATC clearance and f light plan in IFR conditions 14 CFR § 91.203 Civil aircraft: Certifications required 14 CFR § 91.207 Emergency locator transmitters 14 CFR Part 91, Subpart E Maintenance 

### The Extent of Relief Sought, and Reasons for Seeking the Exemption. 14 CFR Part 21, Subpart H. Part 21 establishes the procedures for issuance of certificates of airworthiness, as mandated b y 49 U.S.C. § 44704. Under Section 333 and 49 U.S.C. § 44701(b), the FAA may exempt aircraft from airworthiness certification. The petitioner requests an exemption from the requirements of this Part because the size, weight, speed, operational capability and proximity

to airports in which the Subject UAS pose significantl y less risk than the risks posed by conventional aircraft. Manned aircraft pose ris ks to the life and safety of the crew; that is not a consideration with the Subject UAS. Risks to third parties are also minimized given the lightweight and slow speed at which the Subject UAS would operate, n or are there risks of fuel spillage or fire in the event of an accident. Thus Ms. Felmlee requests that the FAA waive the requirement that the Subject UAS, particularl y the aircraft portion, require an airworthiness certificate. 14 CFR Part 36. FAR Part 36, Subparts A, F, and O, establish certain noise standards for certification of various aircraft ty pes. Because the Subject UAS would not have an airworthiness certificate, and given its small size and negligible noise impact, the petitioner requests an exemption from FAR Part 36.14 CFR § 45.23. FAR Part 45.23 establishes marking requirements for aircraft; paragraph (b) mandates that the registration number be displayed in letters not less than two inches in height. The Subject UAS is small enough that it cannot accommodate the type - size requirement. Ac cordingl y, Ms. Felmlee requests an exemption from this part. 14 CFR Part 61. FAR Part 61 sets forth the certification requirements for pilots. Subpart E establishes the privileges and limitations for holders of a private pilot certificate. The petitioner requests an exemption that would allow her to operate the Subject UAS for compensation or hire . Ms. Felmlee will operate the Subject UAS over areas where the owner or owner's representative has requested that the operation occur , or the specific governmental agency

or NGO that has a jurisdictional right to said area . Furthermore, possession of a pilot certificate does not ensure remote control piloting skills. Sh e thus request s exemption from this section. 14 CFR § 91.7. Under FAR 91.7, no person may operate an aircraft unless it is in an airworthy condition. To the extent that "airworthy" is defined as requiring an airworthiness certificate, the petitioner would request an exemption from this FAR for the same reasons identified in her request for an exemption of 14 CFR Part 21, Subpart H. Sh e will not, however, operate the Subject UAS if it is not in a condition for safe flight, as required under FAR 91.7(b). 14 CFR § 91.9. Petitioner requests exemption from the requirement of FAR 91.9, which requires that all aircraft have certain markings, placards and on - board flight manuals for the same reasons as stated in her request for exemption under 14 CFR Part 21, Subpart H, and for a deviation from the marking requirements of 14 CFR Part 36, Subparts A, F, and 0. Additionally , relevant materials will be kept in a location accessible to the PI C in compliance with the regulations. 14 CFR § 91.103. FAR 91.103 mandates certain pre - flight action. Petitioner will take all necessary pre - flight action, but reque sts an exemption from this requirement insofar as it is interpreted as requiring pre - flight actions appropriate to manned aircraft only (e.g., that flights be from an airport, etc.). 14 CFR § 91.105. FAR 91.105 mandates that crewmembers be at designated stations, have safety belts fastened, etc. Petitioner would be at a designated ground station for each mission, but requests an exemption to accommodate the fact that the Subject UAS is unmanned. 14 CF R § 91.109. This FAR requires that all flight instruction be conducted in aircraft that have dual controls, or throw - over controls, with an instructor. From time to time the petitioner will conduct her own refresher training, but requests an exemption inso far as this FAR would be interpreted to require that the ground control station have a second controller or dual control capability . 14 CFR § 91.119. FAR 91.119 sets forth the minimum safe altitudes over various areas. Petitioner requests an exemption from this FAR in order to accomplish the intended functions for which s he seeks an exemption. 14 CFR § 91.121. FAR 91.121 mandates various altimeter settings in order to maintain level flight. Petitioner requests and exemption from this FAR as the Subject UA V will not have an altimeter that matches the requirements of this FAR. Operations with the Subject UAV will, however, maintain altitude below the 300' AGLceiling b y the petitioner monitoring the altitude of the UAS and through the Subject UAS's ability to establish a flight zone that cannot exceed the ceiling. 14 CFR § 91.151. Petitioner requests an exemption from the VFR- flight fuel carrying requirements because the Subject UAS will operate on battery power. Operations with the Subject UAS will, however, maintain a five minute reserve battery

time. 19 CFR § 91.173. Petitioner requests an exemption from the IFR - clearance requirement for flights into controlled airspace. It is possible Ms. Felmlee may operate the Subject UAS in conditions that are IFR within controlled airspace (e.g., a flight on a day with less than three m iles visibility in an area that falls within the Class D airspace of KBFI). Sh e would request that, after contacting ATC for the controlled airspace, s he would be allowed to operate in what might be IFR conditions, but where s he still has complete and unfettered line of sight visibility with the Subject UAS. 14 CFR § 91.203. FAR 91.203 requires that a civil aircraft have an airworthiness certificate and a registration certificate. Ms. Fe lmlee requests that s he be exempt from complying with this FAR insofar as it mandates issuance of an airworthiness certificate, for the reasons stated in her request for an exemption under 14 CFR Part 21, Subpart H. 14 CFR § 91.207. FAR 91.207 prohibits op eration of a US - registered aircraft unless it is equipped with an emergency

locator transmitter. Given the limited distance of flights of the Subject UAS, Ms. Felmlee requests an exemption from this FAR. 14 CFR Part 91, Subpart E. FAR 91, Subpart E require s that owners or operators of aircraft have the aircraft inspected at certain intervals, and b y certain mechanics. Petitioner requests an exemption from this Subpart because the Subject UAS has a trouble - shooting and maintenance program that is best execut ed by the owner/ operator, and is simply

different from the maintenance of manned aircraft. Petitioner will, however, maintain a maintenance log and any maintenance records of repair of the Subject UAS , with receipts if applicable. 

## Public Interest and **Benefit Considerations.** Granting this exemption will benefit the public interest in the following ways . Ultra - Small electric -powered unmanned aerial s ys tems collect low altitude video footage with far less risk of injury or property

damage, and far less n oise disturbance than a manned helicopter flight. This UAS weighs less than 3 pounds, carries no fuel or crew, eliminating the risk of fire following an incident or accident due to fuel spi llage; there no risk to an onboard crew; the drone will often be op erating in remote areas, areas that, if a mishap would occur in a manned aircraft, would be difficult for emergency responders to reach in a timel y manner. Since the drone is unmanned, the need for such emergency

response is eliminated.Since many

of her clients and associates are involved with environmental issues, she is aware of the need for proper documentation and research involving areas that are:  At risk of degradation due to manmade or natural circumstances;  Damaged due to manmade or natural circumstances;  Exhibiting damage in riparian areas;  Exhibiting damage that is causing flora or fauna hardships. Conversel y, areas that have exhibited degradation and have undergone reclamation/landscaping/hardscaping efforts must also be documented and res earched

– “before and after” comparisons. Many of these areas are desert in nature; many are in remote areas. The public is benefitted in several unique ways. The public can see these videos, via the Internet and in meetings, in new ways, closer and much m ore detailed than ever before. The videos will also help to document adjacent areas that have not been damaged, thereb y offering a valuable ecological comparison and showcase the need for grants and other funding sources. While “on the ground” observation s and photos are valuable, the emerging drone technologies are allowing a much greater an d detailed views of these areas . As an educational tool, the videos will demonstrate to an interested public the ways areas are damaged and how they can participate and help these areas recover. Additionally , the videos allow not only

NGOs but also the public and granting institutions “before and after” proof of successful efforts. Furthermore, since grant dollars are oftentimes tied to public dollars, these videos woul d demonstrate the direct value of these projects to the taxpayer and officials administering those tax dollars. 

### Why the Exem

**ptions Would Not Adversely Affect Safety.** The proposed operations will not adversel y affect safety for four primary reasons. First, the operations will be conducted in airspace where there is ty picall y no activity among other users of the NAS. Flights are limited to areas over which the owner or owner designee has requested that the Subject UAS operate, so the owners will be aware of the flight operation. Ms. Felmlee full y recognizes the dangers that a small UAV could pose to all ty pes of manned aircraft. There will be a rigid separation between where a manned aircraft can fl y (particularly due to FAR 91.119 which establishes minimum s afe altitudes, to include an absolute prohibition of operating an aircraft within 500 feet of any

structure) and where Ms. Felmlee would operate the UAV. Se cond, the Subject UAS is not a large aircraft. Weighing in at less than 3 pounds, the likelihood that it would damage property or injure a person is low, even in the event of a mishap. Aerial imaging is still something done viamanned aircraft, and the risk there is at least equal if not greater to the risk posed by the proposed operation. Third, the Subject UAS has inherent lost - link capabilities to bring it back to its operating base for each mission. It is a redundant s ys tem for a more foreseeable problem that could arise. Fourth, the Subject UAS will be operated onl y by the petitioner. Ms. Felmlee is an experienced radio controlled pilot with sufficient flight time and experience with the aircraft to conduct a reasonabl y safe operation. 

### Language for Inclusion in the Federal Register. Ms. Felmlee proposes that the following language be included in the Federal Register: Petition for Exemption. Federal Aviation Regulations from which Petitioner seeks exemption: 14 CFR 14 CFR Part 21, Subpart H; Part 36; § 45.23; Part 61; §§ 91. 7; 91.9; 91.103; 91.105; 91.109; 91.119; 91.121; 91.151; 91.173; 91.203; 91.207; and 14 CFR Part 91, Subpart E. Description of Relief Sought: The petitioner is seeking an exemption from the above
- referenced Federal Aviation Regulations to conduct aerial photography using a light, unmanned aerial vehicle to document areas of degradation/reclamation/restoration/landscaping/hardscaping. 

### Conclusion. Ms. Felmlee would like to thank the FAA for considering this request. Please do not hesitate to contact her should there be a need for additional information. She looks forward to working with the FAA in its determination, and to being part of the discussion as the FAA considers how to expand, train, test, register, track and control commercial UAV use in the United States. Respectfully

Submitted, Vicki Felmlee Petitioner

### CHART 1 General Specifications of the **Yuneec Q -**  **550 Pro**

 **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** 

40.0oz (1130g)  **Battery**

5400mAh 3S 11.1V LiPo ( 2 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  **Max imum Flying 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

### Figures 1 and 2
**– Example of Logs and Map**