February 28, 2016

U.S. DOT Docket Management Federal Aviation Administration 1200 New Jersey Ave. SE Washington, DC 20590 Re: Exemption Request Pursuant Section 333 of the FAA Reform Act and Part 11 of the FAA 14 CFR:

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. 4 1 7 (a ) & ( b ) Dear Administrator, On my own behalf as an owner and operator of an Unmanned Aircraft System (UAS), I, W illiam T. Frazier Jr., hereby apply for an exemption to FAA Modernization and Reform Act (FMRA) of 2012, Public Law 112 -95 FEB. 14, 2012, Section 333, only as applicable to the above CFR’s. In pursuit of approval for commercial UAS operations within the United States National Airspace System (NAS), all other appropriate and applicable regulations, current or forthcoming, and limitations described herein shall be complied with and adhered to. **Ap plicant:**  Wi lliam T. Frazier Jr. 850 Lake Village Blvd., #204 Auburn Hills, MI 48326 wtfrazier@hotmail.com (954) 801 -6631**UA S Description**  :

The UAS for which I seek exemption is a Yuneec Q500 4K quad - rotor Unmanned Aerial Vehicl e (UAV), equipped with a 4K camera, GPS receiver, Vision Positioning System , powered by electric battery, and a electric battery powered Remote Controller (RC) with an integrated video touch screen . The aircraft body weighs 2.4 pounds with a maximum forward spe ed of 23 mph (27 kts). Maximum flying time per full battery charge is 25 minutes. Software/firmware support for the drone and controller is provided by the manufacturer via the Yuneec corporate internet website.
**Commerci al Operations:**  Exemption is being sought for the following commercial operations on a contractual basis:
 Aerial photography/videography for public and private commercial and non -commercial real estate activities.

 Aerial photography/videography for public and p rivate engagements and events, including , but not necessarily limited to, weddings and corporate promotional endeavors.

 Inspections of public and private use utilities and industrial sites & equipment.

 Aerial photography/videography for p rofessional journalistic ventures and filmography. Request is being made with the understanding that all operations would be conducted in a limited nature, within a predetermined and controlled environment, with safety measures applied as described herei n. Operations shall be conducted in compliance with all respective industry appropriate regulations
. **Flight Operation Considerations:** All flight operations shall be conducted so as to comply with the following considerations: The UAS will be operate d by a single individual designated as the Pilot- In -Command (PIC). PIC qualifications are described herein.

 A minimum of two (2) persons will be present during each flight to which this exemption request applies. One person shall be designated as the PIC, and at least one additional person will be designated as a visual observer (VO).

 The UAV shall remain within visual line of sight (VLOS) of both the PIC and the VO during the entire flight.

 The PIC and the VO shall be capable of audible commun ication between each other during the entire flight.

 All required documentation shall be in the possession of the PIC during any operation, and shall be made available to the Administrator or law enforcement official upon request.

 UAV shall be programmed and shall remain below 400 feet above ground level (AGL) and within a lateral distance of 1000 feet of the PIC.

 Permission from property owners, including personal property (vehicles, equipment, structures, etc.) over, under or near which operatio ns will be conducted shall be acquired before photography/videography and flight operations commence.

 An assessment of the proposed operational environment shall be accomplished to determine that the flight can be conducted in a safe manner so as to prevent undo risk, harm, or damage to operational personnel, bystanders, or property.

 UAS shall only be operated during daylight hours, with environmental visibility of at least three miles, and with a minimum distance of 500 feet below or 2000 feet horizontally from clouds or similar visual obscuration.

 Current and forecast weather reports shall be consulted within one hour prior to each flight. No flight shall be conducted if any weathercondition prevents the UAS from operating safely.

 Landing o perations shall commence when no less than 25% UAV and/or RC battery power level remains, with landing completed at no less than 15% UAV battery power remaining.

 Should GPS signal be lost during any part of the flight, and the PIC is unable to land the U AV with the RC, the failsafe (Home) mode shall be employed to land the UAV safely.

 Operator shall observe distance from airport requirements. A request to deviate from these requirements shall be made to, and verifiable permission shall be received from the appropriate authority prior to every operation, and a NOTAM shall be filed when necessary.

 Prior to each flight, the UAS, including the flight control ler, shall undergo a pre -flight inspection by the PIC. No flight shall be conducted until it is d etermined the UAS meets the requirements for a safe flight. If, upon inspection, it is determined maintenance is required before a safe flight can be conducted, the UAS will not be operated until maintenance is completed.

 Should a change in any conditio ns during a flight occur which compromises the safety parameters described herein, the flight shall be immediately aborted.

 Any accident or incident as defined under NTSB Part 830 which occurs during an operation under which an exemption is requested sh all be reported to the Administrator in the manner and within the timeframe therein described.

 Any violation of the terms of the Certificate of Authorization (COA) under which flight operations are conducted shall be reported to the FAA’s UAS Integratio n Office (AFS - 80) in the manner and within the timeframe therein described.

 The radio frequency spectrum within which the UAS is operated shall be in compliance with the FCC and/or any other controlling agency. Operations shall adhere to 14 CFR 91.111 and 113 when the UAV is flown proximate to other aircraft.
**Maintenance Considerations:** No operation under which an exemption is requested shall be commenced unless the following maintenance considerations are met:

 All maintenance perfo rmed on the UAS shall comply with the manufacturer’s recommendations. Any maintenance or alteration to the UAV shall be recorded in the aircraft log.

 Any maintenance or alteration critical to the UAV flight characteristics shall undergo a functional test flight, which shall be recorded by the PIC in the maintenance records.

 Each maintenance log entry shall include UAV total flight hours, work description, date the work was accomplished, and signature of each person that performed the work.

 Any repl acement parts not considered accessories shall be acquired from the OEM, or at least meet the specifications of and/or comply with the manufacturers recommendations. Any accessories added to the UAS shall meet OEM approval. No accessories which adversely affect the UAS flight characteristics or hinder safe operations shall be incorporated.

 All manufacturer issued Safety Bulletins shall be complied with.
**PIC Qualifications:** No person shall act as PIC for any flight under which an exemption is requested unless that person meets all of the following minimum qualifications:

 A current FAA issued Recreational Pilot certificate.

 A current Third Class Medical Certificate issued by a FAAdesignated Medical Examiner.

 Successful completion of a flight review as described in 1 4 CFR 61.56 in an aircraft for which PIC is rated.

 2 5 hours total time logged as a UAS rotorcraft PIC, at least 10 hours of which is logged as a multi - rotor UAS PIC.

 5 hours total time logged as a UAS rotorcraft PIC of the make and model to be used.

 3 takeoffs and landings of the make and model of UAS to be used within the preceding 90 days.

 Demonstrated ability to perform evasive and em ergency maneuvers and maintain minimum distances from clouds, people and objects as described herein.

 Possess all required documentation at the Ground Control Station (GCS) and make it available to an Administrator or law enforcement official upon request. **Specific Rules Exemption Request:** Exemption from **14 CFR Part 21, Subpart (H)**  (Airworthiness Certificates) is requested in light of the size, speed, and intended use of the UAS. Exemption from **§ 45.23** is requested due to the small size of the UAV, upon which the recommended lettering size would prove difficult to place. If the Administrator requires a registration number be applied to the UAV, relief from the size requirement will assist in proper placement and clear identification. Exemption from **§ 91.7(a)** is requested since no airworthiness certificate is availabl e for the UAV herein described. Exemption from **§ 91.9(b)(2)** is requested since no pilots or passengers can or will be transported aboard the UAV. All documentation relating to safe flight operations shall be available and referred to at the UAS ground con trol station.Exemption from **§ 91.103** is requested since flights will be restricted to VFR,

runways are not required, and no manufacturer performance data is available. Exemption from **§ 91.119** is requested since the UAV shall be operated below 400 feet AGL, in controlled areas with safe distance from people, animals, vehicles and objects. Exemption from **§ 91.121** is requested since the UAV does not have a settable altimetry system, but uses a GPS barometric sensor. The GPS altitude of the UAV shall be tra nsmitted to and observed on the electronic device linked to the RC. Exemption from **§ 91.151(a)** is requested since the UAV operates solely on battery power. Two low battery alerts are issued at the ground control station. The landing phase shall commence immediately after the first alert (no less than 25% battery power remaining), and landing shall be completed either manually or automatically prior to the second alert (greater than 15% battery power remaining). Exemption from **§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b)** is requested since maintenance inspections apply to aircraft with an airworthiness certificate. Operational requirements for the UAV shall include a pre-flight inspection prior to every flight. **Public Interest:** Considering the growing interest in drone (UAV) usage for many different applications , both private and commerci al , the operations I seek exemption for will prove valuable to a number of public and private entities . To perform the above mentioned functions using conve ntional aircraft is far more expensive, time consuming, pose a greater risk and are a less efficient use of resources. Fu rthermore, the environmental footprint that the UAV will impose is minimal while maintaining an extremely high level of public safety. And further, to operate an UAS under a set of regulated mandates and rules will build a level of trust and confidence between the public, the UAV operator, and the Administrator
. **Summary :** As a professional, responsible and knowledgeable individual with an aeronautical

background , I wo uld like to extend my knowledge in aviation to the field of small UAS. By requesting this exemption, I wish to promote the com mercial application of an UAS under the strict guidance of the rules proposed and established for their use. I believe that through strict and responsible adherence to the manufacturer’s operational recommen dations an d the rules implemented by the Administration, an important and valuable service to both public and private customers will be provided and present the opportunity for me to act as an advocate for the safe, efficient, and effective utilization of an UAS, th e importance and reach of which is only beginning to be realized
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