RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of the Federal 

Aviation Regulations. 

Petitioner: Mr. Richard Pelupessy- Wave Technical, Inc. (WTI) 

13340 Pergola Ave 

Bakersfield, CA 93314 

Telephone: 661-885-4038 

Cell: 805-324-1155 

Email:rap@wavetechnical.com 

WTI intends to incorporate the use of UAS commercially for a variety of industries which may include, 

but not be limited to: Oil & Gas, Solar Energy, Nuclear Energy, Power distribution, Telecommunication, 

Agriculture, Farming and Public Safety. UAS Aerial missions may include but not be limited to: 

Geographical mapping, thermal imaging, inspections and monitoring, aerial surveying, remote sensing 

projects, aerial filmmaking, construction monitoring, inspection of critical infrastructure, gas leak 

detection, oil leak detection, wildlife and forestry monitoring photography and real estate purposes, 

search & rescue operations, etc. 

Specific Section(s) seeking exemption: 

14 C.F.R Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b)(2) 

14 C.F.R.91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) and (b) 

14 C.F.R. 91.215 

14 C.F.R. 91.104 through 91.417 

Petition for FAA Section 333 Exemption Page 1 
conduct commercial operations of UAS meeting or exceeding all operational and safety requirements 

per Section 333. 

Public Benefit: 

1. Oil & Gas process management, inspections and monitoring. The use of UAS in Oil & Gas 

operations can improve the safety of workers, environmental safety, local residents and general 

public by assessing potential dangerous situations. In some cases, UAS may reduce or eliminate 

the use of helicopters or small aircraft currently being used for pipeline patrol; 

2. Telecommunications project and construction management, inspections and monitoring of 

critical telecommunications infrastructure. The use of UAS can improve the safety of workers, 

local residents and general public by assessing potential dangerous situations. UAS can be used 

to provide tower inspections and can reduce falls and injuries related to that type of operations. 

In some cases, UAS may eliminate the use of helicopters or small aircraft to perform similar 

functions; 

3. Environmental Review projects. The use of UAS during the process of reviewing projects as 

required by 24 C.F.R. 50.4, 58.5 and 58.6 would provide a more in-depth Environmental Review 

of the project site as well as surrounding areas. Reliance of helicopters or small aircraft may be eliminated; 

4. Aerial surveying. The use of UAS in connection with aerial surveying of smaller areas may 

eliminate the use of helicopters or aircraft. This could provide a more cost effective, safer and 

can be more energy efficient; 

5. Agricultural projects. Wildlife and Forestry projects. The use of UAS could assist with surveying 

agricultural projects as well as wildlife and forestry projects by providing information on 

environmental impacts due to drought, crop condition, insect assessment, vermin infestation, 

fire hazards, etc.; 

6. Remote Sensing projects. The use of UAS could provide data collection for remote and in 

accessible areas. This could promote worker safety as well as reduce the reliance on helicopters 

and aircraft; 

7. Aerial filmmaking, photography and real estate purposes. The use of UAS may provide a point of 

view previously unavailable through other means. They would be more cost effective, efficient 

and more safely than helicopters and aircraft; and 

8. Search and rescue. The use of UAS may provide assistance to local public safety organizations 

during search and rescue missions. UAS may reach areas unattainable or viewable with 

helicopters and aircraft. UAS may be implemented quicker as time is of the essence during 

search and rescue operations. 

Petition for FAA Section 333 Exemption Page 2 
less than thirty (30) minutes as the UAS will continuously monitor battery reserve and return to the 

ground station with at least 20% battery power reserved; 

4. Flights will be operated at an altitude of 200 feet AGL. Flights will never exceed 400 feet AGL; 

5. Minimum crew for each operation will consist of the UAS pilot and a Visual Observer; 

6. A briefing will be conducted daily by all personnel working with said UAS; 

7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written 

consent will be required of all persons within 100 feet of flight operation; 

8. Written and/or oral permission from relative property owners will be obtained prior to operating the 

UAS; 

9. All permits, permissions, etc. will be obtained from local government offices as required; 

10. The UAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.)and 

11. The UAS will operate at speeds less than 50 knots, hover and simultaneously move vertically and 

horizontally; 

12. The UAS will have the capability to return and land at the pre-determined location with the Security 

Perimeter should the UAS lose communication or GPS signal during any operations; 

13. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies; 

14. Operations will not be conducted over densely populated areas or heavily traffic highways; and 

15. Operations will not be conducted within five (5) NM of an airport or heliport. 

WTI will adhere and comply by all regulations including the following: 

1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness Certificates; 

2. 14 C.F.R. 45.23 Display of marks; general and 45.29 Size of marks; 

3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial 

pilot privileges and limitations; 

4. 14 C.F.R. 91.7 Civil aircraft airworthiness; 

5. 14 C.F.R. 91.9 Civil aircraft flight manual, marking and placard requirements; 

6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests; 

7. 14 C.F.R. 91.119Minimum safe altitudes: general; 

8. 14 C.F.R. 91.121 Altimeter settings; 

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions; 

10. 14 C.F.R. 91.203 Civil aircraft: Certifications required; 

11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness certificates: 

Instrument and equipment requirements; 

12.14 C.F.R. 91.215 ATC transponder and altitude reporting equipment and use; 

13. 14 C.F.R. 91.401 Applicability; 

14. 14 C.F.R. 91.403 General; 

15. 14 C.F.R. 91.405 Maintenance required; 

16. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or alteration; 

17. 14 C.F.R. 91.409 Inspections; 

Petition for FAA Section 333 Exemption Page 3 
companies. 

Richard A. Pelupessy- President/CEO and private pilot since 1987 and has logged hundreds of hours in 

private single engine aircrafts. Currently consulting as a Solution Engineer and UAS aviation advisor for 

a large Energy company. Richard also has several hours of flying experience in UAS platforms. 

Larry C. Clever- Chief Pilot and UAS Operations Manager. Former military (Air Force) pilot and is a flight 

instructor certificated by the FFA as a Commercial pilot, CFII, with Single and Multiengine, Instrument, 

ratings and a Gold Seal endorsement. He has accumulated over 10,000 hours of total flight time as an 

instructor and commercial pilot. In addition, he holds an MBA in Information Technology Management. 

Larry also has several hours of flying experience in UAS platforms. 

Proposed UAS Platforms for WTI Flight Operations: 

1. Yuneec Q500 4K 

2. Yuneec Tornado H920 

3. DJI Spread Wings S1000+ 

4. 3DR SOLO 

Petition for FAA Section 333 Exemption Page4 
Typhoon Ancraft 

Dimension 

Flight Time 

Weight with Banery and Payload 

Weight without Banery and 

Payload 

Banery 

Charger 

Transminer 

3 Flight Modes 

Maximum Flying Height 

Maximum Rotation Rate 

Maximum Roll Angle 

Operating Temperature Range 

Radio Control Frequency Band 

Max.DescentSpeed 

Max. Flight Speed ~2625~; ' ' t;P I ltl:;i 330mm Cll Olnl up to 25 minutes 60.0 oz (1700g) 40.0 oz (11 30g) 5400mAh 35 11.1 V LiPo lmcluded) 

420mm 

C16.Sin) 

210mm 

<8 linl 

35 1 1.1 V UPo DC Balancing Smart Charger with AC Adapter (Included) 

10- channei 2.4GHz with 5.8GHz video downlink (mcluded) 

Smart (Follow Me and Watch Me), Angle and Home 

Default 122m {400ft) above Ground Level (AdJustable v1a the Typhoon GUI) 

65"/ S 

35' 

-5"C to BO'C 

2.4GHz 

2m/ s 

Sm •s 

Petition for FAA Section 333 Exemption Page 5 
Type 

Operating System 

Number of Channels 

Control Transmission Range 

(Optimum Conditions) 

Robust Radio Control Modulation 

Video Unk Frequency Band 

Video Transmission Range 

(Optimum Conditions) 

Flight Systems Telemetry Data 

On Screen Display 

LED Backlit LCD Screen 

Taaile (Vibrating) and Audible 

Feedback 

Built- in UPo Battery Voltage 1 

Capadty 

Screen Resolution 

Camera Settings 

5T10+ 

Android"" 

10 

FCC Compliance Up to BOOm (2624.67 ft) CE Compliance· Up to 400m (1312.34 ft) Warning You Must 

Follow Local laws and Maintain VIsual Lme of Sight of Aircraft at All Times 

Yuneec Protocol 

5.8GHz 

FCC Compliance Up to 600m (1968.5 ft) CE Compliance· Up to 300m (984.252 ft) Warning You Must 

Follow Local Laws and Maintain VIsual line of Sight of Aircraft at All nmes 

Yes 

Capacitive Multi-touch 5.5" 

Yes 

3.6V/ 5200mAh 18.72Wh 854 x 480px 

White balance, light exposure, ISO, shutter speed, video resolution, FPS, record video, take pictures 

Petition for FAA Section 333 Exemption Page 6 
Flight Time 

Dimension Diagonal length Without Rotor Blades 

Propeller/Main Rotor Diameter 

Weight with GB603, GH4 camera and Banery 

Banery 

Charger 

Trans miner 

4 Right Modes 

Maximum Flying Height(Absolute altitude) Maximum Flying Height( Relative altitude) 

Maximum Rotation Rate Maximum Roll Angle Maximum Horizontal Speed 

Radio Control Frequency Band 

Operating Temperature Range 

Petition for FAA Section 333 Exemption 

24 mm 

31 4x36.2x18.1 m {797x920x461 mm) 

36.2 111(920mm) 

1 7 3 m (440mm) 

176 4 oz (SOOOgl 

liPo 6s 

65 22.2V UPo DC Balancmg Smart Charger With AC Adapter 

uncluded) 

24-channel 2.4GHz wirh 5 8GHz video downllnl.. (mcluded) 

Smart,Angle,Thronle,and Home Modes 

4000m (I 3124 ft) 

IOOOm(3281 ft) 

100' 5 

35 

21m 5 4 ?MPH 75 KPH (Sky, throttle) 2.4GHz 

5'C to so·c 

Page 7 
Frame 

Moror 

ESC 

Foldable Propeller 

(1552!1552R) 

Frame lvm Weigllr 

Moto<. ESC. Pn>peilO!f l 

Center 

Center Frame W"'':llt (With Mountirq; Base. 

...,...,., 

Stator SiZe 

KV 

MaxWeirtlllwith Coolrrc FanJ 

Signal Frequency 

SiZ.e 

Petition for FAA Section 333 Exemption 

3S6mm 

33,mm 

152!Jg 

460fnH>!Lel'gtlt)•Sltmn1M"dth)•305Jnm,He glnt 

SOO'.V 

1531; 

cSitl'o 3GHl 450Hz 

BKrll 

35g 

1S 5 linen 

Page 8 
Hover Time 

Gatn Value Setttngs For A2 Fbght Controller 

Petition for FAA Section 333 Exemption 

15min (@15UOOrr,.Ah & 9 SKg TakeoffV.e1ghtl 

10 ·c ·40 ·c 

B..ls1r Rolll2016 P rch 120%:, Yrm UC1tl 

Roll170';,t Pitch 170%_1Jernca! lln% 

BaSI"- Rolll:lmo Pitch 130lt, Y;m120'l> 

Art rude Roll Pitch 180% 120% 

Page 9 
Specs; 

Cameras Compatible with GoPro® HER03, 3+ and 4, opt<m!Zed for HERQ3.,. and 4 

Streaming VIdeo qualny 720p 

Flight t<me 25 m<nutes, 20 m<nutes With payload" 

Range 5 m<les·· ( 8 km) 

Max speed 55 mph (8g kmlh) Max ascent speed 10 mls in stabif<Ze mode, 5 mls in "fly" mode Max descent speed dnto 

Max payload 420 g 

Max almude 400ft per FAA regulanon, user adjustable (1 22 m) 

Motors. 880 kV 

Propellers_ 1 0" d1ameter 4 5" pnch seH-ughtenll'lg (24 em diBilleter 144 em pnch), glass-relflforced nylon 

AutopilOt P1xhawk 2 

Software APM Copter 

Commumcat10n. 3DR u nk secure WaF• network 

Frequency: 2 4 GHz 

We1ght 3 3 lbs (1 .5 kg)/ 3 g lbs (1.8 kg) w1th GoPro® and Solo G1mbal 

D1mens•ons 10 In ta" (25 em), 18 1n (46 em) motor-to-motor 

Fl<ght banery Uth1um polymer 5200 mAtt 14 8 Vdc 

Banery charge time - 1 5 hours 

Controller banery 2500 mAh 7 2 Vdc rechargeable lnhlum 10n 

App reqw ements O S 8 0 or later I Android 4 3 or later 

"Flight t<me vanes wnh payload. wind condmons, elevat<on. temperature, humldny, flying style and P<lot skill Usted fl1ght nme applies to elevations 

less than 2. 000 ft above sea level 

.. Depend1ng on environmental conditions, controller 1s expandable, allowing us or th<rd pan<es to amp up the range m the fUiure 

Solo Smart Banery: 

Rechargeable lnh<um polymer (LI-Po) 

5200 mAh 

14 8 Vdc 

We<ght 1 lb ( 5 kg) 

Solo Gimbal: 

Three-ax1s stab<hzatiOn 

Fully compatible wnn 3DR Solo and GoPro HERQ3.,. and HER04, camera charg<ng and stabllJZatlon only wl!h HER03 HDMI v<deo output 

Woreless software upgrade through Solo 

Contro!able range 0' to .go• pl!ch 

Petition for FAA Section 333 Exemption Page 10 
Mr. Richard Pelupessy 

Wave Technical, Inc. 

13340 Pergola Ave 

Bakersfield, CA 93314 

Telephone: 661-885-4038 

Cell: 805-324-1155 

Email:rap@wavetechnical.com 

Petition for FAA Section 333 Exemption Page 11