November 4, 2015 

United States Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey 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 of Intel Corporation under Section 333 of the FAA 

Modernization and Reform Act, 49 U.S.C. 44701(f), and 14 C.F.R. Part 11 

As counsel for and on behalf of Intel 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 Register publication 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 company headquartered 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 ofthe UAV industry. 

RobertS. Strauss Building 1 1333 New Hampshire Avenue, N.W. 1 Washington , D.C. 20036-1564 I 202.887.4000 I fax 202.887.4288 I akingump com 
Intel Petition for Exemption 

November 4, 2015 

Page 2 of7 

The name of the applicant is: 

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 or no adverse effect on safety 

Unmanned Aerial Vehicles 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 of safety as compared with manned aircraft and meet the criteria in section 

333. 

Each UA V (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 exemption to Clayco, Exemption No. 11109, at page 10: 

1 We believe the FAA has in its possession the manufacturer/user manuals for each UAS sought to be operated 

under the requested exemption other than the AscTec Firefly and Hummingbird. 
Intel Petition for Exemption 

November 4, 2015 

Page 3 of7 

The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk 

to an onboard pilot and crew during an incident or accident is eliminated with the use of a 

UAS for the aerial operations. 

For the reasons outlined above, Intel also seeks an exemption from the certification requirements 

for normal category rotorcraft 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 inspect the 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 if the inspection reveals a condition that adversely affects the safety of operations, 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. It will record all maintenance, alterations, and 

the functional flight test in the UAS logbook, including total flight hours, description of work 

accomplished, and the signature of the 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 of sight of the pilot in command and 

observer and below 400 feet AGL. In addition, the flight controllers are programmed not to 

allow the aircraft to exceed the 400 feet ceiling, even if the pilot command input is in-conflict, or 

if communication 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 brief periods of time, within 

the battery capacity of the UAS. 

UA V 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 UA V, and flown the particular UA V for at least 5 hours. In 
Intel Petition for Exemption 

November 4, 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 of sight of the 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 below 400 feet AGL. 

Intel will also notify the appropriate Flight Standards District Office "("FSDO") and/or Air 

Traffic Control for any operation within five miles of an 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 of any person who 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 other than populated or congested, and not closer than 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 or open air assembly of persons. 

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 of sight of the pilot and an 

observer, Intel submits that its operational limitations provides an equivalent level of safety to 

that provided 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 marketing 
Intel 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 of harm to pilots as 

well as persons and people on the ground that would be present during the operation of mmmed 

helicopters. UAS operations will also require a much smaller energy footprint than with manned 

helicopters. 

Operations limited to the United States 

Under the requested exemption, Intel will operate its UASs within the United States. 

Summary for Federal Register 

Because petitioner 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 should be subject to summary handling, thereby obviating publication of a 

summary in the Federal Register and public comment. 

Copy to: Natalie Cheung