### Please find enclosed a revised submission letter based on response to your comment letter. This is related to Docket FAA-2015-6114

. ,iFebruary29,2016 U.S. Department ofTransportation DocketManagement System West Building Ground Floor, Room w12-140 1200 NewJersey Ave, SE Washington, DC 20590

Re: Section 333 ofthe FAAReform Act of2012

DearAdministrator,

I, Charles E. Jenkins, herein referred to as (the petitioner), am writingpursuant to the FAAModernization andReform Act of2012 and the procedures contained within 14 C.F.R., Section 333 FAA reform Act and Part 11 Federal AviationRegulations (part 61.113 ,part 91.7, part 91.119, Part 91.121, Part 91.151, and 14 CFR SubpartE (§§ 91.401-417) ). Request that the petitioner, Charles E. Jenkins, an owner and operator ofa small unmanned_aircraft system (sUAS), petition for.cxemption from the FederalAviation Regulations listedbelow and any regulation as requiredbythe FAAthat is deemed necessary in order to conduct commercial UAS operations as described.

The requested exemption wouldpermit the petitioner to pursue, safe, professional, for profit services to private and public entities within the State ofVirginia and adjoining states utilizing a small unmanned aircraft system (sUAS) for aerial still and video data capture.
Types ofOperations *Real Estate Photography *Municipal WaterTankInspections *Residential/Commercial Roofinspections *Crop Inspection/Damage Survey *Property Survey *Exterior Structure Fire Survey andRural Emergency Operations Aid in case ofNatural Disaster assistance to local public entities.

Commercial and Public Benefits: As described herein, the petitioner operates a Service DisabledVeteran Owned Small Business, located in the HUBZone ofPage County, Virginia. The petitionerhas operatedthis business for over 15 years inthis location. The services offered will be inthe bestpublic interest due to the limited availability, response time andprohibitive cost ofmanned gircraft that adversely affectthe economic competitiveness ofthe area. Our services canbe offeredmuch cheaper, safer, and with reduced noise and pollution than manned aircraft.

• Low operating costs offers better market competiveness

• Zero emissions

• LowNoise

• Greatlyreduced hazard to people or property vs. manned aircraft

• Safe operations is number 1priority with controlledrules and operating conditions



### 1,J,.._ sUAS Desciption: The initial (sUAS) to be utilized during the operations is a consumerclass helicopter, quad-rotor aircraft. It is manufactured byYuneec, Inc. and has the manufactures model designation Q500 Typhoon. Itis an advanced (sUAS) with state ofthe 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 lowbattery. Aircraft LED visual alert indicators for lowbattery, GPS loss, and communication loss. The UAS has a first person view on the controller that is notto 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 ifneeded. 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 LengthW\0 RotorBlades Propeller/MainRotorDiameter Weight W /0 andPayload Battery Maximum Flying Height Radio Control Frequency Band Maximum Groundspeed

STlO Personal Ground Station
Operating SystemAndroidTM Number ofChannels 10 Control Transmission Distance/Range FCC Compliance: CE Compliance: Video linkFrequency Band Video TransmissionDistance/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 11.1V 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 ScreenDisplay (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 petitionerrequests exemption to operate a Yuneec, Q500 Typhoon equipped with a three-axis CGO Gimbal and Camera, bothproducts ofYuneec. This sUAS has apre-programmed limit for the altitude above ground level at 400 feet and a Geo fence while in Smart Mode with a distance limit of300 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 FAArequirement for Visual Line ofSight limitation and an AGL limitation. The ground station is also programmed with a safety feature that disables motor start up ifwithin Class B, and C airspace boundaries. The Q500 also has the failsafe-automated feature ofreturnto home in the event that communication is lost between the ground station and the aircraft.



### 2Safety:

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 ofsight ofthe pilot and observer withoutuse ofa 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 otherUAS aircraft that may enter the UAS operating area. The UAS flight will be immediately terminated ifa potential conflict may exist. d. Operate overprivate orpublic sites only with priorpermission 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% ofbattery capacity or when the 1st low battery alert occurs perthe 

### QSOO Typhoon InstructionManual, not to exceed 18 minutes runtime. g. Operate at a ground speed of0 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 ofthe 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 bythe administrator for private pilot knowledge testing, to the observer and orUAS.



### 3Title 14 Code ofFederalRegulations exemptions requested:

Thepetitioner requests exemption from 14 CFRpart 61.113 Private Pilot Privileges, Pilotin Command Section (a). The petitionerrequests 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.

Thepetitionerrequests exemption from Title 14 CFRpart91.7(a) Civil AircraftAirworthiness. As

no Airworthiness Certificate is available for this sUAS the petitionerrequests exemption under this part utilizing apreflight inspection and the manufacturers documents for determining compliance ofthe sUAS airworthiness. The petitionerwarrants compliance to part 91.7(b) in that the operation will only be conducted after a thoroughpreflight and pre-missionplanning inspection is completed, to include current and forecast weather, airspace, notams, area ofoperations, and notice issued to non-participatingpersons 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.

Thepetitioner requests exemptionfrom 14 CFRpart91.119(c) Minimum SafeAltitudes. The petitioner requests exemption from Section (c) with the following conditions and limitations. The petitioner requests the exemption due to the scope ofthe operations to be performed and the requirementto 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 ofthe sUAS, would provide an equivalent or greater level ofsafety as intended under this part.

The Q500 is a helicopter as defined by CFRTitle 14, FAR Part 1, general definitions. The sUAS has a vertical to near vertical descent in the event ofapower failure. Fly-a-ways would be the greatest ormost dangerous risk to non-participating persons. The Q500 has no documented (fly-away), while operated under GPS lock within the parameters ofthe 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 ofcontrol procedure as described in the emergencyprocedures checklist, adequate time to complete the procedure would exist due to the 0 to 15 mph operational groundspeed ofthe Q500. The risk to persons 100 feet away would be at no greater risk thanpersons located 500 feet away. The petitioner requests exemption from the 500-foot altitude restriction and the 500-foot stand offrestriction from persons, property orvessel applied to previous grants ofexemptions. The exemption is requested with the following conditions and limitations in conducting the petitioners operationsa. The sUAS will be operated at an altitude ofno more than 400 feet above ground level. b. The sUAS will notbe operated at greater than a 400-foot slant distance from the PIC.

c. The sUAS will notbe operated over any non-participatingperson. d. The sUAS will notbe operated over a non-participating property, structure orvessel 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. ofaltitude. 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 ofa crash. f. A minimum of2 hournotice will be distributed to adjacent residences orbusinesses ofa scheduled operation in an urban business or residential area within 500 feet ofthe operation, informing ofthe time, location and safety hazards to persons orproperty, the notice will include a phone number to voice objections orconcerns. g. Warning signs will be displayed on the perimeter ofthe safety zone to alertpassers-by ofthe hazard and warning to stayback and behind cover. Ifthe safety zone is breeched, flight will be immediately terminated. h. The sUAS will be operated over public rural lands with the same stand offdistance and altitude restrictions afforded persons, property and vessels per e. above.



### 4The petitionerrequests exemption from 14 CFRPart 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 orbelow400 feet AGL, combined with the petitioner's intention to limit the altitude ofthe UAS through flight limit function on the UAS, has beenpreviously 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 onboardthe aircraft, and/or a static pressure sensor (barometer), which aids in estimating the altitude.

The petitioner requests exemption from 14 CFRPart 91.151, Fuelrequirements for flight in VFR conditions,priorreliefhas been granted for manned aircraft to operate at less than the prescribed minimums, including ExemptionNos. 2689, 5745, and I0650. In addition, similarVAS-specific reliefhas been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner'sUAS provides lowbattery warnings that indicate the PIC must commandthe UA'sreturnto the launchpoint when lowbattery capacity voltage is reached. The UAS also provides 2 and

3rd increased intensity critical lowbattery warnings through audio and vibration indicating that the UA mustbe landed immediately, additionally a fail safe automatic landing will occur when the battery is at absolute critical lowvoltage. The petitioner warrants that the sUAS will be landed immediately upon the 1st lowbattery alert orno 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 powerto fly at normal cruising speed to the intended landing point and land the UA with 30%batterypowerremaining.

The petitionerrequests exemptionfrom 14 CFR SubpartE 

### (§§ 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) Maintenancerecords. Currently the manufacturers maintenance procedures govern preflight withno limits otherthan on-condition. The petitioner will complete all authorized componentreplacements at the petitioner's base ofoperations or in the field as required. The manufacturer or authorizedrepair center will complete any maintenance or repairs that cannotbe completed by the petitioner. The petitioner warrants thatpreflight, post flight and maintenance procedures set forth shouldprovide an acceptable level ofsafety for the operations performed and is consistent with those ofprevious grants. In addition the petitioner will comply with any and all manufacturers updates for UAS and Ground station as well as any FAAdirectives and guidelines. An appropriate aircraft/maintenance logbook will be kept with the sUAS ground station and base ofoperations

as required.

Summary:

As previously stated the petitioner is an Honorably DischargedVeteran operating a small business in a historically depressed area. The petitioner requests the administrator to considerthat the professional standards and safe practices utilizedbythis petitioner would be an asset and greatlybenefit the development and integration ofthe sUAS system into the National Airspace. Furthermore it is ofthis petitioner'sbest interest to promote safe, compliant and professional commercial operations for the furtherance ofpublic safety in the sUAS industry. This exemption wouldpermit the operations ofa sUAS in areas away from the general public, airports and vehicular traffic. Operations wouldbe conducted within federal guidelines after carefullyreviewing, inspecting, and examining the area ofoperations to ensure public safety ofpersons andproperty.
Sincerely,

Charles EdgarJenkins 506 SouthThird Street Shenandoah, Virginia, 22849 540-652-2103



### 5