U.S. Department of Transportation

Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

October 8, 2015

Re: Exemption Request of Section 33 3 of the FAA Reform Act of 2012

Dear Sir or Madam: I, Hai Nguyen (the petitioner), am writing pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, Hai Nguyen an owner and operator of a small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed above so that I, Hai Nguyen, may operate my small ultra

- light weight unmanned aircraft system (“sUAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”). The requested exemption would permit the petitioner to pursue, safe, professional, for profit services to private and public entities within the State of Connecticut and adjoining states utilizing a sUAS for aerial still and video data capture for, but not limited to the following purpose: A) Real Estate Photography and Video for Realtors and Brokers B) Property Photography and Video Survey for Town, Municipals, Business Owners C) Photo/Videography of rural contracted outdoor scenery on private and public use lands (Prior Permission and coordination) D) Photo/Videography of social events contracted outdoor activities on private and public use lands (Prior Permission and coordination)
As described herein I , Hai Nguyen, am a data and GIS analyst for a Real Estate Advisor Firm for over 2 years. Also, I am a co

- owner of OOTO (Out of the Ordinary) doing advertising and marketing for various clients. In my spare time I have been operating a sUAS as a hobbyist for a total of 2 years in sUAS sa nctioned parks and following all the necessary FAA hobby/recrea tional safety guidelines. With these experiences I would like to broaden my service offerings to my clients, who range from lo cal business owners, Realtors, Town and M unicipals, Academia. The use of sUAS could fulfill a service to consumers and small ent ities that would otherwise not exist due to the risks and costs involved with manned aircraft. The sUAS to be utilized during the operations is a consumer class helicopter, quad

- rotor aircraft. It is manufactured by Yuneec, Inc. and has the manufactures m odel designation Q500 4k Typhoon. It is an advanced (sUAS) with state of the art safety features, GPS lock, altitude, position hold stabilization, smart mode, angle mode follow me and return to home mode. The ground station has telemetry with altitude, gro undspeed, GPS location and battery life for both the transmitter and aircraft as well as an audible and vibration alert for aircraft low battery. Aircraft LED visual alert indicators for low battery, GPS loss, and communication loss. The UAS has a first pe rson view on the controller that is not to beused for flight by the PIC. The UAS has the ability to link with a smartphone or tablet for video link

separate from the on board display if needed. The UAS has separate radio frequencies for telemetry and vide o downlink and aircraft control. See the following manufactures specifications. **Yuneec Q500 4k Typhoon, Quad Copter Specifications** Flight Time Up to 25 Minutes Height 240mm (9.45 in) Width 420mm (16.54 in) Diagonal Length W\O Rotor Blades 565mm (22.2 in) Propeller/Main Rotor Diameter 330mm (13.0 in) Weight W/O and Payload 1130g (40.0 oz) Battery 5400mAh 3S 11.1V LiPo 3 Flight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet AG L (Adjustable via the Q500 GUI) Maximum Rotational Velocity 65°/s Maximum Bank Angle 35° Maximum Climb Rate in Smart and Angle mode 3m/s Maximum Descent Rate in Smart and Angle mode 2m/s Takeoff Weight With Battery and CGO3 1700g (60.0 oz) Radio Control Frequency Band 2.4GHz Maximum Groundspeed 15 MPH
**ST10 Personal Ground Station Specifications**  Operating System AndroidTM Number of Channels 10 Control Transmission Distance/Range FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Robust Radio Control Modulation Yuneec Protocol Video link Frequency Band 5.8GHz Video Transmission Distance/Range (Optimum Conditions) 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 Times. Flight Systems Telemetry Data On Screen Display (OSD) Yes LED Backlit LCD Screen Capacitive Multi

-Touch 4.5” Tactile (Vibrating) and Audible Feedback Yes Built

- In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh **CGO3 Camera Gimbal System** Focusing System Aerial Optimized Fixed Focus Video Field of View 130° Transmission Band 5.8GHz Video Transmiss ion Distance/Range FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) with ST10 UAS are often seen as superior to manned helicopters due to the smaller size and lower costs, reduced noise and as such, a much smaller env ironmental and safety impact.The petitioner requests exemption to operate a Yuneec, Q500 4k Typhoon equipped with a three

- axis

CGO3 Gimbal and Camera, both products of Yuneec. This sUAS has a pre

- programmed limit for the altitude above ground level at 400 feet and a Geo fence while in Smart Mode with a distance limit of 300 feet from the controller. These limits are preset at the factory and will be kept at those limits, which currently comply with the AMA’s and FAA requirement for Visual Line of Sight li mitation and an AGL limitation. The ground station is also programmed with a safety feature that disables motor start up if within Class B, and C airspace boundaries. The Q500 4k also has the failsafe

- automated feature of return to home in the event that c ommunication is lost between the ground station and the aircraft.

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The petitioner will

-- A) Only operate its UAS in direct visual line of sight of the pilot and o bserver without use of a visual aid other than corrective lenses. B) Operate at an altitude no greater than 400 feet above the ground. C) Operate with due vigilance and known practiced see and avoid scanning techniques to avoid any conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UAS flight will be immediately terminated if a potential conflict may exist. D) Operate over private or public sites only with prior permission from property owner or owner’s agent or legal au thorities as allowed by law. E) Terminate flight when any unsafe condition exists. F) Terminate flight when battery voltage drops to 30% of battery capacity or when the 1st low battery alert occurs per the Q500 Typhoon Instruction Manual, not to exceed 18 minutes run time. G) Operate at a ground speed of 0 to 15 mph during on site missions. H) Operate in accordance with the guidance and standards set forth by the AMA, the UAS manufacturer and the administrator. I) Operate with a minimum crew for each operat ion consisting of the PIC and a visual observer in direct communication utilizing appropriate verbal, radio or cell phone as needed. J) Insure the sUAS operator on the controls will be at least a current Private Pilot with a class III medical. K) Provide g round instruction with standards and content currently accepted by the administrator for private pilot knowledge testing, to the observer and or UAS.

**Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness.** As no Airworthiness Certificate is available for this sUAS the petitioner requests exemption under this part utilizing a preflig ht inspection and the manufacturers documents for determining compliance of the sUAS airworthiness. The petitioner warrants compliance to part 91.7(b) in that the operation wil l only be conducted after a thorough preflight and pre

- mission planning inspection is completed, to include current and forecast weather, airspace, notams, area of operations, and notice issued to non

- participating persons in local proximity. The petitione r will utilize the Yuneec, Q500 4k Instruction manual, quick start guide and the petitioners own pre -flight checklist included in the attached supplements to determine the sUAS airworthiness.**The petitioner requests exemption from 14 CFR part 91.119(c) Mi nimum Safe Altitudes.**  The petitioner requests exemption from Section (c) with the following conditions and limitations. The petitioner requests the exemption due to the scope of the operations to be performed and the requirement to operate below 400 feet AGL. The Petitioners primary mission would be to record data or survey of persons, property or structures as listed above. The sUAS size, weight, speed and limited operating times and area, as well as the soft materials used in the construction of the sUAS, would provide an equivalent or greater level of safety as intended under this part. The Q500 4k is a helicopter as defined by CFR Title 14, FAR Part 1, genera l definitions. The sUAS has a vertical to near vertical descent in the event of a power failure. Fly

- a -ways would be the greatest or most dangerous risk to non

- participating persons. The Q500 4k has no documented (fly

- away), while operated under GPS lock within the parameters of the Q500 4k operating instructions. The Q500 4k is a very stable, low ro tor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized UAS. In an emergency the sUAS would be quickly brought down per the loss of control procedure as described in the emergency procedures checklist, adequate time to comp lete the procedure would exist due to the 0 to 15 mph operational groundspeed of the Q500 4k . The risk to persons 100 feet away would be at no greater risk than persons located 500 feet away. The petitioner requests exemption from the 500

-foot altitude restriction and the 500

-foot stand off restriction from persons, property or vessel applied to previous grants of exemptions. The exemption is requested with the following conditions and limitations in conducting the petitioners operations

— A) The sUAS will be operated at an altitude of no more than 400 feet above ground level. B) The sUAS will not be operated at greater than a 400

-foot slant distance from the PIC. C) The sUAS will not be operated over any non

- participating person. D) The sUAS will not be operated over a non

- participating property, structure or vessel without prior permission from the property owner or legal representative. E) The sUAS will maintain a minimum slant distance of 100 feet from any non

- participating person and will increase th e distance proportionally by 50 ft. per 50 ft. of altitude. At no time will the sUAS be operated closer than a 100

-foot slant distance to a non

- participating person unless that person is behind a protective barrier or shielded from possible debris in the event of a crash. F) A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled operation in an urban business or residential area within 500 feet of the operation, informing of the time, location and safety hazards to pe rsons or property, the notice will include a phone number to voice objections or concerns. G) Warning signs will be displayed on the perimeter of the safety zone to alert passers

- by of the hazard and warning to stay back and behind cover. If the safety zone is breeched, flight will be immediately terminated. H) The sUAS will be operated over publi c rural lands with the same stand off distance and altitude restrictions afforded persons, property and vessels per e. above. **The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings.** The UAS will not have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA withinVLOS and at or below 400 feet AGL, combined with the petitioner’s intention to limit the altitude of the

UAS through flight limit function on the UAS, has been previously ruled to be a sufficient method for ensuring the UAS operations do not adversely affect safety. The altitude information will be generated by GPS equipment installed onboard the aircraft, and/or a static pressure sensor (barometer), which aids in estimating the altitude. **The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR conditions,**  prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, a nd 10650. In addition, similar UAS

- specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner’s UAS provides low battery warnings that indicate the PIC must command the UA’s return to the launch point when low battery capacity voltage is reached. The UAS also provides 2 and 3 rd increased intensity critical low battery warnings through audio and vibration indicating that the UA must be landed immediately, additionally a fail safe automatic landing will occur when the battery is at absolute critical low voltage. The petitioner warrants that the sUAS will be landed immediately upon the 1 st low battery alert or no longer than 18 minutes which ever occurs first. The petitioner will n ot initiate a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining. **The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401** 

**- 417),) Maintenance required,**  **91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records** 

. Currently the manufacturers main tenance procedures govern preflight with no limits other than on

- condition. The petitioner will complete all authorized component replacements at the petitioner’s base of operations or in the field as required. The manufacturer or authorized repair center will complete any maintenance or repairs that cannot be completed by the petitioner. The petitioner warrants that preflight, post flight and maintenance procedures set forth in the petitioner’s supplements attached should provide an acceptable level of safety for the operations performed and is consistent with those of previous grants. In addition the petitioner will comply with any and all manufacturers updates for UAS and Ground station as well as any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be kept with the sUAS ground station and base of operations as required, (See Supplement).

In summary to commerc ially operate my, Hai Nguyen’s, small unmanned vehicle/lightweight unmanned aircraft vehicle in comm unity awareness a nd real estate operations, and to develop economic platfor ms to enhance the experience of those seeking our services

. I, Hai Nguyen, have been analyzing flight information an d will compile safety protocols and the implementation of a flight operations manu al for real estate usage that exceeds currently accepted means and methods for safe flight. Cur rently, area awareness and real estate aerial videography/photography relies primarily on the us e of larger aircraft running on combustible fuel, p osing potentia l risk to the public. Granting my, Hai Nguyen’s, request for exemption will reduce current risk levels and thereby enhance safety. My sUAS craft do es not contain potentially explosive fuel, is smaller, lighter and more maneuverable than conventional real e state video and photographic aircraft with much less flight ti me. Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk flying to and from established air fields.Accordingly I, Hai Nguyen , respectfully request that the FAA grant my exemption request and am willing

to cooperate in sha ring information to benefit the FAA, safety of manned aircraft, and the general public at large.

Respectfully submitted,

Hai Nguyen
OOTO
1137 Main St. East Hartford, CT 06108