Please find enclosed a revised submission letter based on response to your comment letter. 

This is related to Docket FAA-2015-6114 

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February 29,2016 

U.S. Department of Transportation 

Docket Management System 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Section 333 of the FAA Reform Act of2012 

Dear Administrator, 

I, Charles E. Jenkins, herein referred to as (the petitioner), am writing pursuant to the FAA Modernization 

and Reform Act of2012 and the procedures contained within 14 C.F.R., Section 333 FAA reform Act and 

Part 11 Federal Aviation Regulations (part 61.113 , part 91.7, part 91.119, Part 91.121, Part 91.151, and 

14 CFR Subpart E (§§ 91.401-417) ). Request that the petitioner, Charles E. Jenkins, an owner and operator 

of a small unmanned_aircraft system (sUAS), petition for.cxemption from the Federal Aviation Regulations 

listed below and any regulation as required by the FAA that is deemed necessary in order to conduct 

commercial U AS operations as described. 

The requested exemption would permit the petitioner to pursue, safe, professional, for profit services to 

private and public entities within the State of Virginia and adjoining states utilizing a small unmanned 

aircraft system (sUAS) for aerial still and video data capture. 

Types of Operations 

*Real Estate Photography 

*Municipal Water Tank Inspections 

*Residential/Commercial Roof inspections 

*Crop Inspection/Damage Survey 

*Property Survey 

*Exterior Structure Fire Survey and Rural Emergency Operations Aid in case of Natural Disaster assistance 

to local public entities. 

Commercial and Public Benefits: 

As described herein, the petitioner operates a Service Disabled Veteran Owned Small Business, located in 

the HUBZone of Page County, Virginia. The petitioner has operated this business for over 15 years in this 

location. The services offered will be in the best public interest due to the limited availability, response 

time and prohibitive cost of manned gircraft that adversely affect the economic competitiveness of the area. 

Our services can be offered much cheaper, safer, and with reduced noise and pollution than manned 

aircraft. 

• Low operating costs offers better market competiveness 

• Zero emissions 

• LowNoise 

• Greatly reduced hazard to people or property vs. manned aircraft 

• Safe operations is number 1 priority with controlled rules and operating conditions 

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,J,.._ 

sUAS Desciption: 

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 on 

board display if needed. The UAS has separate radio frequencies for telemetry and video downlink and 

aircraft control. See the following page for manufactures specifications. 

Yuneec 0500 Typhoon, quad copter 

Flight Time 

Height 

Width 

Diagonal Length W\0 Rotor Blades 

Propeller/Main Rotor Diameter 

Weight W /0 and Payload 

Battery 

Maximum Flying Height 

Radio Control Frequency Band 

Maximum Groundspeed 

STlO Personal Ground Station 

Operating System AndroidTM 

Number of Channels 10 

Control Transmission Distance/Range FCC Compliance: 

CE Compliance: 

Video link Frequency Band 

Video Transmission Distance/Range (Optimum Conditions) 

Up to 25 Minutes 

240mm (9.45 in) 

420mm (16.54 in) 

565mm (22.2 in) 

330mm{13.0 in) 

1130g (40.0 oz) 

5400mAh 3S 11.1 V LiPo 

Default 400 Feet AGL 

2.4GHz 

15MPH 

Up to 800m (2624.67 ft) 

Up to 400m (1312.34 ft) 

5.8GHz 

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 

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 CGO 

Gimbal and Camera, both products ofYuneec. This sUAS has a pre-programmed limit for the altitude 

above ground level at 400 feet and a Geo fence 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 limitation. 

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 between the ground station and the aircraft. 

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Safety: 

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 conective lenses. 

b. Operate at an altitude no greater than 400 feet above the ground. 

c. Operate with due vigilance and known practiced 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. Tenninate flight when battery voltage drops to 30% of battery capacity or when the 1st low 

battery alert occurs per the QSOO 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 

manufacturer 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. Provide ground instruction with standards and content cUITently accepted by the administrator 

for private pilot knowledge testing, to the observer and or UAS. 

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Title 14 Code of Federal Regulations exemptions requested: 

The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, Pilot in 

Command Section (a). The petitioner requests consideration that this is waived due to the training and 

adherence to established rules for sUAS commercial operations whereas private pilots operating a manned 

aircraft are limited to non-commercial operations. 

The petitioner requests exemption from 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 and 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 

pre-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 conditions 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 structures 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 has 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 conducting the 

petitioners operationsa. 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 will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time 

will the sUAS be operated closer than a 1 00-foot slant distance to a non-participating person 

unless that person is behind a protective barrier or shielded from possible debris in the event 

of a crash. 

f. A minimum of 2 hour notice will be distributed to adjacent 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. 

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The petitioner requests 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 installed 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 manned aircraft to operate at less than the prescribed 

minimums, including Exemption Nos. 2689, 5745, and I 0650. In addition, similar VAS-specific relief has 

been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) 

conditions. 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 

3rd 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 

1st 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 landing 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, 

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 petitioner'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 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 updates for U AS 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. 

Summary: 

As previously stated the petitioner is an Honorably Discharged Veteran operating a small business in a 

historically depressed area. The petitioner requests the administrator to consider that the professional 

standards and safe practices utilized by this petitioner would be an asset and greatly benefit the 

development and integration ofthe sUAS system into the National Airspace. Furthermore it is of this 

petitioner's best interest to promote safe, compliant and professional commercial operations for the 

furtherance of public safety in the sUAS industry. This exemption would permit the operations of a sUAS 

in areas away from the general public, airports and vehicular traffic. Operations would be conducted within 

federal guidelines after carefully reviewing, inspecting, and examining the area of operations to ensure 

public safety of persons and property. 

Sincerely, 

Charles Edgar Jenkins 

506 South Third Street 

Shenandoah, Virginia, 22849 

540-652-2103 

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