### Petition for Exemption 14 **CFR § 11.81**

**Submitted By**: Ross Anderson **Ad dress**  : 927 Gay Street Longmont, CO 80501 **Phone:** 720 -203-4090 **Email Ad**  **dress** : ross@allaerialphoto.com 

## Seeking	Exemption	from: 14 CFR Part 21, Subpart H
- Airworthiness Certificates **14 CFR Part 91 Subpart A** §91.9 Civil aircraft flight manual, marking, and placard requirements. **14 CFR Part 91 Subpart B** 91.103(b)(2) Preflight action 91.105 Flight crewmembers at stations 91.109 Flight instructio n 91.119 Minimum safe altitudes 91.121 Altimeter settings 91.151 Fuel requirements for flights in VFR conditions 91.405 Maintenance required 91. 407 Operation after maintenance 91.409 Inspections 1.417 Maintenance records 

## Extent	of	Relief We are requestin g relief from above rule s as it’s not possible to obtain an airworthiness certificate for an ai rcraft of this type. And I do not believe this aircraft can meet many of the requirements set forth in part 91 as listed above. The extent of our relief is the following:We would like the ability to operate our aircraft while following the same rul es set forth for model

aircraft in addition to the items listed in attached document Operating Procedures – Safety.docx **Summary of Model Aircraft Rules Below:**

 Fly below 400 feet and remain clear of surrounding obstacles  Keep the aircraft within visual line of sight at all times  Remain well clear of and do not interfere with manned aircraft operations  Don't fly within 5 miles of an airport unless you contact the air port and control tower before flying  Don't fly an aircraft that weighs more than 55 lbs .  Don't be careless or reckless with your unmanned aircraft – you could be fined for endangering people or other aircraft Our specific intended uses
- Operating Procedures – Safety Section 1.0 : 1. Real Estate Photos/Video 2. Sports Video 3. Entertainment – Take people for a “ride” in a drone. 4. Agriculture – Precision farming and general farm management. 

## General	Benefit	to	the	Public If approved this request would benefit others in the following ways: 1. Sellers of homes would have the ability to get current photos of their properties at reasonable prices. 2. Buyers also benefit from current photos to properly asses a property. 3. Real Estate Agents can give a better visual representation of the property which benefits buyers and sellers of real estate. 4. Videos and pictures can be used in many areas of sales and marketing for Colorado. **Farming:** 1. Better crop assessment in regards to nutrients, natural disasters, and general health. Also kn own as precision farming. 2. Livestock control and accountability. 3. Pasture assessment. The approval of this request also promotes local entrepreneurship which will benefit the local community.

## Reasons	why	the	exemption	would	not	adversely	affect	safety, **or	how**

**the	exemption	would	provide	a	level	of	safety	at	least	equal	to	the existing	rule**  This exemption would not adversely affect safety for the following reasons: 1. The PIC is a certificated pilot who makes good decisions based on the safety of people and other peoples’ property. 2. The aircraft this exemption request is for, is built by airplane manufacturers, and has an outstanding safety record. With a large user base of this aircraft type, there is lots of test’s and information available. 3. This i s not a homebuilt aircraft. It is built by a reputable manufacturer with an outstanding safety record for their drones and recreational aircraft. 4 . I have just over 150 hours flight time with this aircraft for recreational purposes. 

## A	summary	we	can	publi**sh	in	the Federal	Register**  We would like an exemption from 14 CFR Part 21, Subpart H regarding the Airworthiness Certificate. We don’t believe it’s possible to obtain an AC for this type of aircraft. We are asking for permission to operate under the same rules set forth for model airplanes today, only we will be using the aircraft for commercial purposes. We have 4 specific intended uses which include Real Estate Photos/Videos, Sports Video to be used in sales/marketing, Entertainment and Agriculture . I believe the approval of this exemption would benefit the local industries in the above paragraph. Small agile aircraft that can take high quality photos and video give a perspective not seen before, or p reviously impossible to obtain. These photos could help enhance tourism, real estate sales, and many other local business. We don’t believe this will adversely affect the safety of others or their property due to the PIC ability to make good decisions abou t safety, and the outstanding safety record of the aircraft being flown. The “drone” we are flying is built by a reputable business operating since 1999. Based out of Hong Kong with facilities all over the world, Yuneek has been building manned electric ai rcraft since inception. They have a lot of experience building flying machines. 

## Any	additional	information,	views,	or	arguments	available	to	support **your	request** My only view on the situation is this is a safe operation. We have a safe reliable aircraft w ith a responsible pilot. I have been flying it for a couple months without any malfunctions. It has outstanding safety features and general user interface. I have been building and flying RC airplanes and multi
-copters for approximately 6 years. As a private pilot and aviation enthusiast, I have spent a lot of years in thegeneral aviation environment. I understand the rules, safety precautions, and general respect of ot her

people and their property. 

## Regarding	the	Unmanned	Aircraft	System This operation will be safely conducted by following the rules set in place for all Model Aircraft. Very few people are hurt or property damaged around the world by following these rules. Also see Operating Procedures – Safety.docx Section 2.0

 Fly below 400 feet and remain clear of surrounding obstacles  Keep the aircraft within visual line of sight at all times  Remain well clear of and do not interfere with manned aircraft operations  Don't fly within 5 miles of an airport unless you contact the airport and control tower before flying  Don't fly near people or stadiums Stadiums with prior permission .  Don't fly an aircraft that weighs more than 55 lbs  Don't be careless or reckless with your unmanned aircraft – you could be fined for endangering people or other aircraft **Ai rcraft Information:**  URL to Manufacturer
- http://www.yuneec.com/index.html Make/Model
– Typhoon Q500
- http://www.yuneec.com/products/AerialUAV/q500

-typhoon.html Manual – Click Here**Aircraft Specifications:**

I n addition to the Quick Start Guide as a pre
-fligh t check list before each flight the steps outlined in Operating Procedures – Safety.docx Section 4.0 Pre
- Flight Safety Considerations Quick Start Guide **FCC Information/Radio Frequency** This device complies with part 15 of the FCC rules. This aircraft contains a radio transmitter with wireless technology which has been tested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.400GHz to 2.4835G Hz frequency range. The camera sends the signal back on a 5.8 GHz wireless connection. 

## Regarding	the	Unmanned	Aircraft	PIC The PIC, Ross Anderson is a certificated Private Pilot with 450 hours PIC Time. I have been building and flying RC aircraft and Multi
- Rotor aerial photography platforms for 5 years with approximately 1000 hours flight time. The PIC, Ross Anderson also holds a third class medical certificate.

## Regarding	the	Operation	of	the	Unmanned	Aircraft

We are intending on using this aircraft for the following purposes: **Real Estate Photos and Videos** – We would like the ability to take aerial photos/video of properties for buyers and sellers of homes. Precautions – Not all properties are good candidates for aerial photography. We will implement a process of evaluating jobs based on safety. If the property is in a congested area, we may not be able to get the shot. **Entertainment –**  We would like the ability to take people for “Rides” in this aircraft. The customer would put on goggles that display the vi ew from the camera, and the pilot would fly around. This gives the customer an “in
-flight” view, and true sensation of flying without leaving the ground. Precautions – This has to be done in the right location away from hazards. Flight paths are away from people and not over them. **Action Shots and Videos** – This aircraft could be used for kayaking, mountain biking and other action sports. We feel these videos and photographs can be used to promote Colorado business. Precautions – The main precaution here i s communicating with the athletes and spectators if there are any. If it is a public event, advanced planning must be done. **Precision Farming –**  We do not have the ability to process imagery, but we do have the ability to take the pictures. I would like to take pictures of crops, and have them processed for precision farming. **P lan for operating safely without endangering the public**  : 1. Assessment is made to determine if a safe flight is possible. 2. Preflight Briefing on what to expect from takeoff to landing for any people in the area. 3. Get all needed permission. 4. Clear takeoff and landing pad is identified. 5. Flight Path should never go directly over people or property. 6. Flight Plan is understood by PIC before taking off. 7. For public events, the landing pad is blocked off from people. 8. For public events proper planning is done to verify clear flight path to photo location. Clearly defined Operational Borders can be found on attached document Operating Procedures – Safety.docx Section 2.0 The maximum operating speed is 10 mph. The maximum operating altitude is 400 feet AGL – Safety mechanism on aircraft. Tested and works as expected. In regards to cloud clearness, I would follow Basic VFR stated in 14 CFR 91.155.Real Estate photography and Entertainment presents the most flight hazards. In some cases we could be

asked to fly near other people’s homes and cars. These hazards will have to be mitigated on a case by case basis. Many country homes have few to no hazards where downtown properties have many. The following proced ures are used when assessing a flight. 1. Maintain a safe distance from all homes . 2. Never fly above anything without permission. Example: You may have to fly above the customer’s car to get the shot, which is ok providing you have permission and explaine d the consequences. It is not OK to fly over the neighbor’s car. 3. Never Fly above groups of people. 4. Have multiple “outs” to land the aircraft in case of emergency. Other areas of operation for action shots and agriculture happen in much less populated areas. Farms and fields present few dangers other than the customer’s property. Before signing a contract, the customer needs to understand the risks of flying this aircraft on their property. These risks will be documented in their contract. The customer will be provided a suitable structure to hide in case the aircraft has an emergency. I always follow the General Safety Precautions and Warnings from the Manufactures Quick Start Guide and Manual . **Operating Around Airports –**  I do intend on operating aroun d airports . Regular RC Airplanes are permitted at airports with approval from the Airport Manager. Safety precautions: The opportunity may arise when we need to operate in the vicinity of an airport or even at an airport. Some of these situations could be aerial shots of jets for sale, or video of a skydiver landing their parachute. 1. PIC Ross Anderson must have the ability to hear the CTAF and communicate with pilots in the area 2. PIC Ross Anderson shall make a call on the airport CTAF to advise pilots of th e flight and intentions. 3. The radio call to local traffic should include:  Location relative to the airport. Accurate as possible.  Intended Altitude of Flight  Intended Length of Flight  Approximate operating radius 4. In the event of aircraft operat ion at an airport, the airport manager must be contacted and rules 1 - 3 above apply. The airport manager has the option to stop the flight.**Maintaining Visual LOS (Line of Sight)** – This aircraft is not designed for long range flights . Proper flight

p lanning is required to maintain VLOS . This aircraft has a safety mechanism “Return To Home.” This can be activated by the pilot or automatically if the aircraft loses radio connection. This aircraft also has a safety function that will not allow you fly ou t of range. **Preflight Safety Risk Assessment –**  Operating Procedures – Safety.docx Section 4.0 The pre
-flight procedures are stated in the manufactures document Quick Start Guide . In addition to these recommendations the PIC Ross Anderson will perform the following procedures before each flight: 1. Assess the environment for hazards. This includes automobiles, people, yards with fences etc. 2. Have a flight plan in mind. Know and understand how the picture or video will be taken before take
-off. 3. Evaluate all safe landing zones. 4. Have a plan for maintaining VLOS (Visual Line of Sight)