1
, Submitted electronically

October 26, 2014

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

RE: Petition for Exemption from Certain Federal Aviation Regulations according
to Section 333 of the FAA Modernization and Reform Act of 2012

Dear Sir or Madam:

Dynamic Aerial Services ( DAS ) is applying for an exemption from the Code of
Federal R egulations as detailed below

.

The exemption would permit commercial operation of a small unmanned aircr aft system ( S UAS) in the national air s pace (NAS) as regulated by the FAA for aerial data collection, for the following uses:

I. Remote sensing and measuring by an instrument(s) aboard the UA including

A. imagery (photography, video, infrared, etc.)

B. electronic me asurement (precision inspection , RF analysis, etc.)

C. chemical measurement (particulate measurement, etc.)

D. or any other gathering of data by instruments aboard the UA

.

II. Assisting in maintaining public safety in times of emergency including

A. a erial photography and evaluation of emergency response scenes and operations with DAS agreement

B. aid in e mergency servi ces support and search and rescue with DAS

agreementDAS333a102615 2 All operations performed by are cost effective and protect the public by reducing the
size of the airc raft from one weigh ing up to several tons to one weigh ing less than 55 pounds. In addition, the UA does not use flammable liquid fuel. Instead, it operates on high

- energy batteries. The UA is flown in the low er strata of controlled and uncontrolled airspac e, at 4 00 ft. AGL and below. DAS c ommercial operations will be performed according to FAA regulations or amended FAA regulations as permitted
under a Section 333 Grant of Exemption.

BACKGROUND AND REFERENCES

In support of the petition and the FAA’s eval uation process, we reference previously granted 333 exemption petitions by the FAA with same or similar purposes as follows :

• Aerial digital imagery, survey, and inspection: exemption no 11992, Aerial
Check UAVs

• Further commercial purposes for safety and p ublic awareness of UA uses; exemption no. 11409, Wade Bell

• E mergency services support and search and rescue exemption no. 12515, RPA/UAS Consulting LLC

DESCRIPTION OF PETITIONER

Dynamic Aerial Services is owned and operated by Joel Davis. DAS provides c ommercial
aerial data collection services to its customers and clients

. DAS is headquartered in the greater St. Louis, Missouri area. In addition, Mr. Davis provides training services for UA operators in safety and flight operations. Mr. Davis holds a comm ercial pilots license.

NAME OF PETITIONER

Joel Davis 317 Willowpointe Dr ive

St Charles

, MO 63304DAS333a102615 3 AGENT FOR DAS

For technical and administrative questions on this petition, please contact:

Mr. Brian Dyer

RPS

- West

Email: Brian.Dyer@RemotePilotSystem s.com

DAS requests a Summary Grant of Exemption for the Yuneec Typhoon Q500 4K.

Thank you for your time and attention.

Sincerely

,

Brian DyerDAS333a102615 4 DESCRIPTION OF UNMANNED AIRCRAFT SYSTEM S

DAS wishes to fly in its operations :

• The Yuneec Typhoon Q500

as its inspection aircraft.

The Yuneec Typhoon Q500 4K

The Typhoon Q500 4K is a vertical takeoff and landing unmanned aircraft of quadcopter design. Manufactured by Yuneec International Co. Ltd., the Typhoon Q500 4K has the
world's first Smart Transmitter (the "ST

- 10 series Ground Station" with 10 channels) combining a 2.4GHz radio control transmitter with a 5.8GHz digital video link. It operates on a built

- in Android touch screen. Safety features include Geo Fencing, Home
Mode and Return Home. Geo Fencing prohibits the aircraft from exceeding a programmed permitted radius. When activated, Home Mode will automatically return the
aircraft within a 10

- foot radius of its starting point. Should the transmitter signal be lost

or visual li ne of sight with the aircraft impaired, upon signal, Return Home will automatically take control of the aircraft and return it to the operator/base station.

Takeoff weigh t with manufacture provided camera and gimbal payload and battery is 3.75
lbs.

The Ty phoon Q500 4K dimensions are 9.45 in (210mm) x 16.54 in (420mm)

, with a diagonal of 20 in (510mm) from motor to motor. It can fly up to 25 minutes on its 5400mAh 3S 11.1V lithium polymer battery. Radio control and video transmission systems meet FCC requir ements for operation in the unlicensed spectrum of 5.8 GHz ranges. The operating manual of the Typhoon Q500 warns against using the aircraft in areas where radio interference is possible, as does the Flight Operations manual ( FOM)

, along with procedures to ensure radio safety with the UAS.

EXTENT OF RELIEF SOUGHT AND WHY

DAS asks for relief from regulations tabled below, which the authority of the FAA has previously granted in exemption certificates number 11062 along with six others
described as “in c ommonality”, and in number 11109, which are for use of electricDAS333a102615 5 rotorcraft. The FOM incorporates the conditions and limitations of these grants of exemption, and in some cases imposes stricter limits on its own operations.DAS333a102615 6 CFR CODE CITATIONS

14 CFR
PAR T SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF
SAFETY

61.113 (a) Private pilot privileges and limitations: pilot in
command Holder of private pilot certificate may not act as pilot in command (PIC) for compensation or hire. Flying for compensation

on inspection missions is central to purpose of exemption request. Characteristics of aircraft, VLOS, under 400 ft. AGL, trained visual
observer in radio communication with pilot; remote site, construction industry safety protocols enhanced by flight safety plan; PIC with airman’s certification, appropriate medical and vision qualification, currency
in the aircraft listed on the certificate, pilot training, testing, proficiency with similar and same model UA; and inspection/maintena nce are defined in the and will ensure equivalent levels of safety.

61.113 (b) Private pilot privileges and
limitations: Pilot in
command Holder of private pilot certificate may act as PIC for compensation or hire if flight is incidental to
business or e mployment and does not carry passengers for compensation or hire. Flying for compensation

on inspection missions is central to purpose of exemption request, not
incidental to business or employment. There is no passenger or pilot on
board the UA , thus saf ety issues are different from a manned flight.
DAS ’s aircraft have programmable automated safety features and emergency responses, have pre

flight checks for safety beyond commercial manned aircraft, can be geographically restricted by operator with progra mmable control points, have
communications with the PIC regarding fuel loss and other flight hazards. PIC will have ground school training certificate and additional 25 hours logged flight
time and 25 hours classroom and
field instruction as stated in the

FOM

.DAS333a102615 7 14 CFR
PAR T SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF
SAFETY

91.119 (c) Minimum safe
altitudes over other than congested

area Operating closer than 500 feet to a person, vehicle, or structure may be necessary
for pipeline and equipment inspection. People will not be allowed over,
under or within 500 feet later ally of the aircraft in flight. Some flights may require the participation or guidance of industry personnel, positioned as close as 200 feet, will brief them on safety and obtain necessary consent. Industry site safety rules
will be followed.

91.121 Alt imeter settings Procedures to set and
confirm altitude do not provide for operation of remote telemetry to SUAS pilot. An onboard air pressure sensor and software resolve height
differences as small as one
centimeter. Altitude is controlled by measuring air pressure and the

z

- axis accelerometer/GPS values. The starting point is a relative height measurement calculated by the flight controller. Altitude above ground is displayed on the pilot's handheld controller by telemetry, and alarms can signal
conditi ons of interest. 4 00 feet AGL is the maximum permissible
in the FOM , which describes altimeter procedures.DAS333a102615 8 14 CFR
PAR T SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF
SAFETY

91.151 (b) Fuel requirements for flight in VFR
conditions Rotorcraft under VFR must carry enough fuel to reach first landing point
and then anoth er 20
minutes. The multirotor aircraft specified in this petition is designed to fly
missions of 25

- minute
durations. On aircraft specified, battery voltage under load is displayed on the pilot's handheld controller during flight. Battery chemistry
does n ot support adequate current discharge below about 3 v per cell. Circuitry in the onboard flight controller measures voltage and will start a failsafe procedure to
land before summed minimums
are reached. In the event that one or more cells fail, these mini mums may be reached sooner than expected, due to rapid current drain against a smaller number of functioning cells. DAS pilots are trained to monitor voltage and recognize abnormal discharge in flight and to land sooner than
forced. If 20 minutes of flight tim e or 25% of reserve voltage under load is reached, pilot must commence landing.

91.405 (a) Maintenance required Required inspections and discrepancies repaired
between the required inspections pertain to
certificated manned aircraft and procedures
conduc ted by licensed maintenance personnel. In
the absence of certification requirements for SUAS
and SUAS maintenance personnel, reasonable
alternatives must be developed to maintain equivalent levels of safety. DAS will document maintenance, overhaul, replac ement and inspection requirements in the
absence of manufacturer's requirements; will document and
maintain maintenance records and technician qualification criteria in
the FOM

.DAS333a102615 9 14 CFR
PAR T SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF
SAFETY

91.405 (b) Maintenance
records Qualifications for maintenance personnel fo r SUAS were not contemplated by these regulations, and a
reasonable alternative must be developed to maintain equivalent levels of safety. Qualifications, competence and testing for maintenance personnel
are defined in the FOM

.

91.407 (a) (1) Operatio n after maintenance, preventive maintenance, rebuilding, or
alteration There is no authorization procedure for a person who can approve a return to service of an SUAS, and
a reasonable alternative must be developed to maintain equivalent levels of safety. Procedures for the PIC to test then approve a return to service
after maintenance are defined in
the FOM

.

91.409 (a) (1) Inspections Annuals conducted by a qualified inspector require
authorization criteria for that inspector, not yet
defined for SUAS . A
reasonable alternative must be developed to maintain equivalent levels of safety. Schedules for inspection and responsibilities of the PIC and qualified technician are described
in the FOM

.

91.409 (a) (2) Inspections Issuance of airworthiness

cert ificates for SUAS under 55 pounds operated VLOS is not contemplated by these regulations Airworthiness is the responsibility
of the PIC and the technician as
defined in the FOM

.DAS333a102615 10 14 CFR
PAR T SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF
SAFETY

91.417 (a) Maintenance
records Regulations do not contemplate requirements or approval processes for
maintenance and inspection of uncertificated SUAS,
however a reasonable
alternative must be developed to maintain equivalent levels of safety. The operator will maintain records according to the procedures specified in the FOM

.

91.417 (b) Maintenance
records Retaining and transferring
records of maintenance and defects according to standards prescribed for
authorized maintenance and inspection is not contemplated in the regulations for SUAS. A
reasonable alternative is

necess ary to maintain equivalent levels of safety. Records and documentation will be kept for all maintenance performed, defects, and for all components specified in the

FOM

.

PILOT IN COMMAND AND CREW

The pilot in command (PIC) must hold an a ir man’s certi fication recognized by the FAA

such as an airline t ransport , commercial, private, recreational, sport pilot, or glider pilot (powered or non

- powered) and must comply with the training and testing specified in the

FOM . The PIC must hold a current FAA airma n medical certificate as required by the class of airman certification. In the case of the sport pilot certification, the PIC must

possess a valid U.S. driver’s license issued by a S tate, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must comply with the training and testing specified in the operator’s manual. The PIC must remain in radio
communication with a visual observer who complies with the training and test ing specified in the operator’s manual. The pilot must be able to acquire the aircraft with hisDAS333a102615 11 own vision according to eye standards for a third class airman medical certificate or valid driver’s license according to the issuing State

. The PIC must operate within visual line of sight only, and be able to see the attitude and orientation of the aircraft by himself . If GPS or magnetometer is compromised, certain safety features may not operate, and the pilot must understand by their training and experience how to recover control.

OPERATION OF T HE UNMANNED AIRCRAFT

The aircraft will be under the operational control of DAS ’ s PIC

.

1. Operations for the purpose of closed

- set motion picture and television filming will not be permitted.

2. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). Either groundspeed or calibrated airspeed will be used to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft
manufacturer.

3. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude will be reported in feet AGL.

4. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical
certificate or U.S. driver’s license.

5. All operations will utilize a visual observer (VO). The UA will be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO will be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC will be able to c ommunicate verbally at all times; electronic messaging or texting will not be permitted during flight operations. The PIC will be designated before the flight and will not transfer his or her designation for the duration of the flight. The PIC will ensure that the VO can perform the duties required of the VO.

6. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in an approved grant of exemption, are hereinafter referre d to as the operating documents. The operating documents will be accessible during UAS operations and made availableDAS333a102615 12 to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the granted exemption(s) and the proce dures outlined in the operating documents, the conditions and limitations in the granted exemption will take precedence and will be followed. Otherwise, the operator will follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. The operator will track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The operator will also present updated and revised documents if it petit ions for extension or amendment to a granted exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the requested exemption, then the operator will petition for an amendment to its grant of exemp tion. The FAA’s UAS Integration Office (AFS

− 80) will be contacted if questions arise regarding updates or revisions to the operating documents.

7. Any UAS that requires maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights will only be conducted by a PIC with a VO and will remain at least 500 feet from other pe ople. The functional test flight will be conducted in such a manner so as to not pose an undue hazard to persons and property.

8. The operator will be responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

9. P rior to each flight, the PIC will conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection will account for all potential discrepancies, e.g., inoperable components, items, or equipment. If the insp ection reveals a condition that affects the safe operation of the UAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

10. The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft
components.

11. Each UAS operated under this exemption will comply with all manufacturer safety
bulletins.

12. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia,DAS333a102615 13 Puerto Rico, a territory, a pos session, or the Federal government. The PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

13. The operator will not permit any PIC to operate unless the PIC d emonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under a granted exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and

struct ures. PIC qualification flight hours and currency will be logged in a manner
consistent with

14. 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s
abil ity to safely operate the UAS in a manner consistent with how the UAS will be operated under will be permitted only under the terms of this exemption. However, training operations will only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16. The UA will not operate within 5 nautical mi les 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 the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or any law enforcement official upon

reques t.

17. The UA 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 3 statute miles from the
PIC.

18. If the UAS loses communications or loses its GPS signal, the UA will return to a

pre

- det ermined location within the private or controlled

- access property.

19. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.DAS333a102615 14 20. The PIC will be prohibited from beginning a flight unless (considering wind and
forecast weather conditio ns) there is enough available power for the UA to conduct the intended operation and to operate after that for at least 5 minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations will be conducted in accordance with an ATO

- issued COA. If operations cannot be conducted under the terms of a granted COA, the operator will apply for a new or amended COA.

22. All aircraft operated in accordance with a gra nted exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

23. Documents used by the oper ator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating.

24. These documents will be made available to the Administrator or any law enforcement official upon request.

25. The UA will remain clear and give way to all manned aviation operations and
activities at all times.

26. The UAS will not be operated by the PIC from any moving device or vehicle.

27. All Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations will cease immediately in a manner ensuring the safety of nonparticipating persons;
and

b. The owner/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 hazard. The PIC, VO,DAS333a102615 15 operator trainees or essential persons are not considered nonparticipating persons under this exemption.

28. All operations will be conducted over private or controlled

- acce ss property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

29. Any incident, accident, or flight operatio n that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable granted COA will be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

BENEFIT TO THE PUBLIC

Approval of this petition all owing commercial operations of S UASs will enhance safety by reducing public safety risk. The use of battery powered UA s fore aerial inspection,

geo

- mapping and image and film cap ture, is more environmentally sou nd and safe compared to a conve ntional, liquid

- fueled aircraft. It provide s a smaller en vironmental footprint, d ecrea ses manpower and separate s the aircraft operators form the air craft. The use of the specified s UA S s furth er protects the public by being used in restricted environments and reducing impact hazards.

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT

SAFETY

The inspection aircraft will be operated in accordance with DAS safety protocols

The inspection aircraft carries no person, cargo, or flammable liquid fuel. Its size and weigh t are a small fraction of any manned aircraft, and its safety systems reflect best design practices in the SUAS industry.

In addition, DAS will keep the approved at its groun d control station. The PIC will have immediate access to it. Previous exemptions granted by the FAA concerning Section 91.9(b) establish that safety is not adversely affected when the approved Aircraft FlightDAS333a102615 16 Manual is kept at the ground control station of a S UAS, where it can be immediately accessed by the PIC.

When properly operated by trained pilots, a well

- designed SUAS can stay clear of people and property on the ground and in the air. Procedures, airmanship skills, training and testing requirements f or SUAS personnel in the will let the operator achieve safety levels in the NAS and on the ground that are equivalent to or greater than that in manned

aviation

SUMMARY FOR PUBLICATION

The following summary may be published in the Federal Register:

DAS requests an exemption from:

14 CFR Parts 61.113 (a) and (b) 14 CFR Parts 91.119 (c), 91.121, 91.151 (b), 91.405 (a) and (b), 91.407 (a) (1), 91.409 (a) (1), 91.409 (a) (2), 91.417 (a)

in order to operate a small unmanned aircraft system (SUAS) for purposes of aerial inspections and monitoring, aerial geo

- mapping

, aerial imaging and filming

, aerial data

collection and public safety in times of emergency. The PIC will be appropriately qualified with a current FAA approved pilot certificate for SUA S operation and specialized training.

Imagery, electronic measurement, chemical measurement or any other gathering of data
to be done by instruments aboard the UA , a re conventionally done by manned aircraft operations, which use liqui d fuel and weigh up wards of 5,000 lbs. These operations must fly the aircraft to and from the operation’s location. The use of the Yuneec Typhoon Q500 4K which weigh s less than 15 lbs. and is equipped with flight control and safet y features tha t prevent flyaways, minimize s the risk from that of a manned aircraft to people and property allowed within and outside the zone of operations.

Flight operations outside the secure areas are not allowed. T here are no impacts to privacy.