November 4, 2015 United States Department ofTransportation Federal Aviation Administration Docket Management System 1200 NewJersey Avenue, NE Washington, DC 20590 Filed in www.regulations.gov 

# AkinGump STRAUSS HAUER & FELD LLP

GREGORY S. WALDEN +1 202
.887.4213/fax: +1 202.887.4288 gswalden@akingump.com

Re: Petition for Exemption ofIntel Corporationunder Section 333 ofthe FAA Modernization and Reform Act, 49 U.S.C
.44701(f), and 14 C.F.R. Part 11 As counsel for and on behalfofIntel Corporation ("Intel"), we hereby seek an exemption from certain Federal Aviation Regulations enumerated below, as authorized by Section 333 of the FAA Modernization and Reform Act ("Section 333"), Subsection 44701(f) of the Federal Aviation Act, and pursuant to the procedures set forth in Part 11 of the Federal Aviation Regulations, to allow Intel to operate the following unmanned aerial vehicles ("UAVs"): the Ascending Technologies Falcon, the Ascending Technologies Firefly, the Ascending Technology Hummingbird, the Yuneec Typhoon Q500 & Q500 4K, the DJI Inspire 1, the DJI Phantom 3 Professional and Advanced, and the 3D Robotics Solo. Intel will comply with the standard conditions and limitations included in numerous Section 333 exemptions granted recently. Accordingly, we respectfully ask the FAA to grant this petition in summary fashion, and obviate Federal Registerpublication and public comment. Intel is one of the world's largest semiconductor chip makers. Intel designs and builds the essential technologies that serve as the foundation for the world's computing devices. It is a global technology companyheadquartered in Santa Clara, CA. Intel is focused on researching and developing new technologies in new markets such as the UAS industry. The purpose for which Intel will operate its UASs is to demonstrate UASs to customers, to capture marketing material, to research and develop new technologies for the future oftheUAV industry
.

RobertS
. Strauss Building 1 1333 New HampshireAvenue, N.W. 1Washington , D
.C. 20036-1564 I 202.887.4000 I fax 202
.887.4288 I akingump comIntel Petition for Exemption November4, 2015 Page 2 of7


### The nameof the applicantis: Intel Corporation Attn: Natalie Cheung, Drone Product Manager MS: RNB 5-03 2200 Mission College Blvd
. Santa Clara,CA 95054 ( 408) 765-2651 natalie.cheung@intel.com 

### Exemptions requested 14 C
.F.R. Part 21 (airworthiness certification) 14 C.F
.R.Part 27 (normal category rotorcraft) 14 C.F.R. 61.113 (a) and (b) (pilot certification and qualification) 14 C.F
.R.91.7(a) (airworthiness) 14 C.F.R. 91.119(b) and (c) (minimum safe altitudes) 14 C.F.R
. 91.151(a) and (b) (fuel requirements in VFR conditions) 14 C
.F.R.91.405 (a) and (b) (maintenance) 14 C
.F
.R.91.407(a)(l) (approval for return to service) 14 C.F.R. 91.409(a) (annual and airworthiness certification inspection) 14 C
.F
.R. 91.417(a) and (b) (maintenance records) 

### Safety equivalence ornoadverse effecton safety UnmannedAerialVehicles and Systems 

### The DJI Inspire 1, DJI Phantom 3 Professional and Advanced, the 3D Robotics Solo, and the Ascending Technologies (AscTec) Falcon UAV Intel seeks authority to operate have each been approved for commercial use in many section 333 exemptions to date. The features of the AscTec Hummingbird and Firefly UAVs are set forth in the AscTec usual manual, which can be accessed on http://wiki.asctec.de/display/AR!User+Manual. 1 

### Given their small size, operational capabilities, and the restricted areas in which the UAVs will operate, an exemption from Part 21 , Subpart H, Airworthiness Certificates, and 14 C.F.R. 91.7(a), is warranted: these UAVs satisfy the equivalent level ofsafety as compared with manned aircraft and meet the criteria in section 333. Each UAV (with payload) is less than 55 pounds, carry no explosive materials or flammable liquid fuels, and would operate outside controlled airspace, with no passengers or crew on board. As the FAA has found in granting an exemptionto Clayco, ExemptionNo. 11109,at page 10:

1We believe the FAA has in its possession the manufacturer/user manuals for each UAS sought to be operated underthe requested exemption otherthan the AscTec Firefly and Hummingbird.Intel Petition for Exemption November4, 2015 Page 3 of7
The limited weight significantly reduces the potential for harm to participating and nonparticipating individuals or property in the event ofan incident or accident. The risk to an onboard pilot and crewduring an incident or accident is eliminated with the use ofa UAS for the aerial operations
. Forthe reasons outlined above, Intel also seeks an exemption from the certification requirements for normal categoryrotorcraft in Part 27
. In support of Intel's request for an exemption from 14 C.F.R. 91.405(a), 91.407(a)(l), 91.409(a)(1) and (2), and 91.417(a) and (b), Intel will adhere to the following inspection and maintenance program: it will inspectthe UAS before and after each operation, as well as perform weekly, monthly, and annual inspections. Before each flight, the pilot in command will inspect the UAS to ensure it is in a safe condition for flight. The preflight inspection will account for any discrepancy, such as an inoperable component, item, or equipment. Intel will not initiate a flight ifthe inspection reveals a conditionthat adversely affects the safety ofoperations, and will not operate that UAS until it is found to be in a safe condition. Any UAS that has undergone maintenance or an alteration that affects the UAS's operation or flight characteristics will undergo a functional flight test before return to service. Intel will follow the manufacturer's UAS requirements relating to components, maintenance, overhaul, replacement, inspection and life limits. Itwill record all maintenance, alterations, and the functional flight test in the UAS logbook, including total flight hours, description ofwork accomplished, and the signature ofthe UAS technician who returned the UAS to service. Intel's UASs are equipped with an altimeter and GPS that provide the pilot with real-time telemetry data in addition to a constant digital display of altitude, speed, and UAS proximity
. Moreover, the UASs will be operated within the visual line ofsight ofthe pilot in command and observer and below 400 feet AGL. In addition, the flight controllers are programmed not to allowthe aircraftto exceed the 400 feet ceiling, even ifthe pilot command input is in-conflict, or ifcommunication with the remote control transmitter fails
. Accordingly, we do not believe an exemption from 14 C.P.R. 91.121 is required. In support oflntel's request for an exemption from fuel requirements in 14 C.P.R. 91.151(a) and (b), we note that each UAS is battery-powered and is operated for briefperiods oftime, within the battery capacity ofthe UAS. 

### UAV and 

### UAS Operator Qualifications and Training In support of its request for an exemption from the pilot certification and qualifications requirements in 14 C.F.R. 61.113(a) and (a), Intel asserts that an equivalent level of safety is achieved by the UAS-specific experience of its pilots. Each pilot, before conducting a commercial operation under the requested exemption, will have performed at least 20 takeoffs and landings of the particular UAV, and flown the particular UAV for at least 5 hours. InIntel Petition for Exemption November4,2015 Page 4 of7
addition, each pilot will hold a valid and current private pilot, recreational pilot, or sport pilot certificate. UA V and UAS Operating Parameters Intel will operate its UASs in full compliance with the applicable manufacturer manual. All flights will be conducted within the visual line ofsight ofthe pilot in command, within noncontrolled airspace. Although the UAS may be operated in a metropolitan area, it will be controlled and monitored only by authorized personnel, and be flown below400 feet AGL. Intel will also notify the appropriate Flight Standards District Office "("FSDO") and/or Air Traffic Controlfor any operationwithin five miles ofan airport. Intel will conduct a briefing before each day's operations, which all personnel participating in the operations must attend. It will obtain written consent ofany personwho will be participating in the operations or otherwise be on the private property where operations are to take place. It will limit its operations to daytime Visual Flight Rules ("VFR"). Intel seeks an exemption from the requirement in 14 C.F
.R. 91.119, subsection (b), that an aircraft must remain at least 1,000 feet above any congested area or open air assembly of persons, and subsection (c), that an aircraft must remain at least 500 feet above any person or structure in an area otherthan populated or congested, and not closerthan 500 feet to any person, vehicle, or structure. These requirements were adopted with fixed-wing, manned aircraft operations in mind
. While Intel may operate its UASs in a metropolitan area, the operations will be carefully pre-planned to minimize risk to persons or property, avoid intrusion into unauthorized airspace, and avoid a public annoyance. Its UASs will not be operated over a highly-congested area oropen air assembly ofpersons. Intel will make every reasonable effort to ensure that no unauthorized person will be on the land over which the UASs will be operated, and will provide notice to adjacent buildings and furnish proctors as may be necessary to ensure that unauthorized persons do not come within the narrow parameters in which the UASs will be operated. Combined with the technological capabilities of the UASs and that the UASs will be operated within the visual line ofsight ofthe pilot and an observer, Intel submits that its operational limitations provides an equivalent level of safety to thatprovided in section 91.119. Public interest The proposed operations to research and develop new technologies serve the public interest by providing a new and safe way for operate UASs, provide new capabilities via sensors and more computing power to create new markets and opportunities for consumers and businesses
. In order to do this, Intel will also need to demonstrate UASs to customers and capture marketingIntel Petition for Exemption November4, 2015 Page 5 of7
material with UASs as well as work with UASs companies to bring these opportunities to the industry. Operating UASs under the limitations proposed by Intel will avoid any risk ofharm to pilots as well as persons and people on the ground that would be present during the operation ofmmmed helicopters. UAS operations will also require a much smaller energy footprint than with manned helicopters. 

### Operations limitedto the UnitedStates Underthe requested exemption, Intel will operate its UASs within the United States. 

### Summary forFederalRegister Becausepetitioner seeks the same authority under the same conditions and limitations as the FAA has imposed with many exemptions, we believe granting this petition would not set any precedent and thus shouldbe subjectto summary handling, thereby obviatingpublication ofa summary in the Federal Register and public comment.

Copy to: Natalie Cheung