Jason Haab

3135 Eagle Creek Dr.

Bloomington, IL 61704

(309) 862-4324

jason@haabair.com

To: Federal Aviation Administration

US Department of Transportation

Docket Management System

1200 New Jersey Ave. S.E

Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam:

Exemption Request Section 333 of the FAA Reform Act Pursuant to section 333 of the FAA

Modernization and Reform act of 2012 (The Reform Act), and 14 C.F.R. Part 11, I, Jason Haab herby

seeks and applies for an exemption to the Federal Aviation Regulations (FARs) to allow JASON HAAB to 

operate Small Unmanned Aircraft Systems (UAS) commercially in airspace regulated by the Federal

Aviation Administration (FAA) under the conditions and limitations set forth in this petition. The

requested exemption would permit JASON HAAB to operate small, unmanned aircraft system (UAS) for

the purpose of providing an aerial photography and survey service to Municipalities, Utilities & Private

consumers. The areas of use will include both photo and video in the Utilities, Communications industry,

real estate industry, surveying industry, construction industry, agricultural industry. The UAS will be

operated in airspace that is 1) limited 2) predetermined 3) would provide added safety enhancements to

the already safe operations in the industry presently using conventional aircraft. 

Exemption request to section 333 of the FAA Reform Act Plan 11 Specific to UAS operations.

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) & (b); 14 CFR 91.103;14 CFR 91.105; 14 CFR

91.109: 14 CFR 91.119(c);14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14

CFR 91.401(a)(1) & (2); 14 CFR 91.417(a) 7 (b).

Intended Use:

Commercial operation of an UAS, as described herein, which are equipped with the camera (s) and 

sensors, would operate in the following manor:

 Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

 Aerial video and/or photography of for public and/or private use including television, public 

events, cinematography and news gathering.

 Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure included but not 

limited to electrical power lines, wind turbines and cell towers.
 Aerial video/photography or providing live video feed to assist with rescue operations in cases 

of an emergency or natural disaster only when the local authorities or government has 

requested it by contract and/or donation.

 The ability to offer training to persons or individuals belonging to both private and/or public 

organizations that have interest in the use and application of UAS for the purpose of the safe 

operation of a UAS to enhance the safety of national airspace system as well as for protection of 

the persons and property.

As described fully below, the requested exemptions would permit the operation of a UAS under 

controlled conditions in the NAS that would be a) limited b) controlled c) predetermined, and d) will 

provide safety enhancements such as limited exposure to flight crew, climbing crews, weight of vehicles, 

speeds of usage, non use of volatile fuels, etc. Approval of this exemption would thereby enhance safety 

and fulfill the Secretary of Transportations and FAA Administrators responsibilities to "...establish 

requirements for the safe operation of such aircraft systems in the national airspace system. 

Unmanned Aerial Vehicle (UAV):

The primary vehicle to be used will be the Lumenier QAV 500v2, battery operated 4-motor quad copter 

that takes off and lands vertically. While vehicles may be upgraded as new technological and safety 

advances occur the bar for operation and safety will be set by Lumenier QAV 500v2 and any new 

vehicles or versions will exceed the current safety and operational standards. The operation limitations 

proposed for an equivalent or higher level of safety because operations will further enhance the safety 

of the persons and/or property using conventional aircraft. These limitations and conditions to which

the applicant agrees to adhere to when conducting commercial operations under the FAA issued 

exemption as set forth in the flight operations manual.

The UAV Includes:

 An on-board flight computer with GPS navigation and location ability that receives signals for 

flight controls from a ground-based transmitter/controller.

 An on-board camera capable of capturing imagery in the form of full color, high definition still 

photos and video.

 An on-board telemetry system that delivers flight data from the on-board flight computer to the 

on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass 

direction of flight and direction back to it launch site.

 FCC Approved 2.4Ghz or 5.8Ghz on-board radio transmitter that transmits live video from the 

on-board camera plus all the flight data from the telemetry system described above. 

Ground Station:

 A Pilot in Command (PIC) in operational control of a mission from beginning to end, and who 

controls the UAV while in the air.

 A 2.4Ghz radio transmitter/controller operated by the PIC to control the UAV while in flight.

 Ground Station which receives and displays video and system telemetry real time from the UAV.

 A Visual Observer (VO), a person who provides a second pair of eyes to visually track the UAV 

while in flight.
Pilot in Command (PIC) and Visual Observer (VO):

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16-Personnel

Qualifications. Additionally, the PIC and VO will perform maintenance on the system and will complete a 

course of maintenance instruction as part of their initial training.

I submit that the combination of the UAV's light weight, flight performance and ability, fully qualified 

flight crew and strict operation under the guidelines established in 8900.227, and under all of the 

restrictions listed above, the FAA can have full confidence that the operation will have an equivalent or 

greater level of safety than manned aircraft performing the same mission.

UAV Operating Guidelines:

The UAV will weigh less than 55 lbs

The UAV will have a maximum operating speed of no more than 100 mph

Flights will be operated within line of sight of the pilot in command and/or visual observer

Maximum flight time for each operational flight will be 30 minutes. Flights will be terminated at

 25% battery power reserve or 30 minutes of flight time whichever occurs first

Flights will be operated at altitude of no more than 200feet above ground level and no more

 than 200 feet above an equivalent platform from which filming is planned.

UAS will NOT operate.

5 nautical miles (NM) from an airport having an operational control tower; or

3 NM from an airport with a published instrument flight procedure, but not an operational tower; or

NM from an airport without a published instrument flight procedure or an operational tower; or

2 NM from a heliport with a published instrument flight procedure

Minimum crew for each operation will consist of the UAS pilot(PIC), the visual observer (VO) and

 may include but not limited to a camera operator

The UAV pilot will be designated pilot in command and hold a private pilot’s license along with a

 Current State Drivers License. If the PIC feels another operator to be qualified with the

 necessary skills to be pilot in command and possesses a private pilot’s license along with,

 Current credentials, that person may be designated PIC provided they have a minimum of 20

 hours of flight time with the UAS.

A briefing will be performed regarding the planned UAS operations prior to each day’s flight

 consisting of all days production activities

All flights will occur under visual flight rules meteorological conditions (VFR only).

The operator will obtain verbal/written consent of all persons involved with the planned

 operations and ensure only consenting persons will be allowed within 100 feet of the flight

 operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety

 determination, as required under the FOM. With the advance permission of the FFDO,

 operations at closer range may be approved.

The PIC and VO will have been trained in operation of UAS and receive up-to-date information

 for the particular UAS to be operated.

The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

Written and/or verbal permission and permits will be obtained from territorial, state, county or

 city jurisdictions, including law enforcement, fire or other appropriate governmental agencies.

If the UAV loses communications with the remote controller or losses GPS signal, the UAV will

 have the capability to return to a pre-determined location within a designated location and land

 autonomously.

The UAV will have the capability to abort a flight and return to designated landing area in case of
 unpredicted obstacles, weather, or emergencies.

VO or PIC instructed to switch UAV to automatically return home in event either are

 incapacitated.

Public Safety:

UAV's are powered by batteries, they are a smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel. They operate at lower altitudes (under 400ft) with no people on board 

thereby reducing current risk levels and enhancing public safety. With a small payload and maximum 

flight time of approximately 20 minutes, UAV's offer little or no risk to national security. In addition the 

Flight Controller has its own built in flight restrictions in special use areas.

Summary Grant Request:

As of March 23, 2015, the FAA will automatically grant a "blanket" COA for flights at or below

200 feet to any UAS operator with a Section 333 exemption, provided the aircraft weighs less

than 55 pounds, operations are conducted during daytime Visual Flight Rules (VFR) conditions

and within visual line of sight (VLOS) of the pilots, and stay certain distances away from

airports or heliports. In seeking authorization, petitioners will require exemptions from regulations with 

which they cannot fully comply. The table below provides guidance regarding regulations from which a 

petitioner may require exemption. However, some proposed operations may require exemption from 

regulations not listed here, while others may not require exemption from all regulations listed here. 

The Regulations from Which the Exemptions are being requested:

14 CFR Part 21Subpart H Certification procedures for products and

parts, Airworthiness Certificates

14 CFR 91.103(b)(2) Preflight action

14 CFR 91.105 Flight crewmembers at stations

14 CFR 91.109 Flight instruction

14 CFR 91.119 Minimum safe altitudes

14 CFR 91.121 Altimeter settings

14 CFR 91.151 Fuel requirements for flights in VFR conditions

14 CFR 91.405 Maintenance required

14 CFR 91.407 Operation after maintenance

14 CFR 91.409 Inspections

14 CFR 91.417 Maintenance

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. Sec 91.203(a)(1)

The UAS will operate @ 55lbs or less (Gross), carries neither a pilot or passenger*, carries no explosive

materials or flammable liquid fuels*, and operates in within a secured and pre-determined designated

area, at altitudes not to exceed 200 ft ALT or speeds in access of 100 MPH.

14 C.F.R. Sec 91.105 Flight crew members at station

Exemption may be required, the PIC may not leave his station nor shall VO leave station . In event that

PIC or VO become incapacitated, UAS is to automatically return to designated landing area, as

outlined in FOM

14 CFR Sec 91.109 Flight Instruction (Dual Controls)

Requiring that no person shall operate a civil aircraft for flight instruction unless the aircraft has full functioning 

dual controls.UAS and Remote controlled aircraft by design do not have dual controls, to
do so on a radio controlled aircraft would lower the ability to safely operate the UAS. This section

cannot reasonably apply

14 C.F.R. Sec 45.23(b). Marking of the Aircraft

Although exemption from said section cannot benefit nor exceed current stipulations, physical

limitations of UAV are reality, such as cabins, letter size, etc. The UAV will operate under my control

with registration lettering sized to fit fuselage in compliance of said section 45.23(b) under conditions

and or limitations deemed mandatory by FAA . I and my colleges must be held responsible for

compliancy, on behalf of Public’s safety and shared air space, as well as its need to indentify and

Enforce the accountability and of this growing industry.

14 C.F.R. Sec 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

By current regulations because the applicants UAS does not carry passengers, or property. The use of

UAS is far less dangerous (weight, speed, Fuel) than the inherent usage of commercial activities

outlined in 14 CFR.16. The pilot in command shall have a current Private pilots license as well as a

Current state drivers license which will equal if not exceed safety regulations outlined in 14 CFR

16.113.(a) & (b).

14 C.F.R. Sec. 91.103: Preflight Action:

Exemption is requested due to fact that FAA rotor flight manuals are not available for UAV. The PIC

will take all actions as stated in FOM, under normal procedures included but not limited to review of

weather, examination of batteries for flight time analysis, landing and takeoff distances as well as

flight and aircraft performance in flight.

14 C.F.R. Sec 91.119; Minimum Safe Altitudes

Mandates safe altitude for operation of civil aircraft and allow helicopter to operates less then

minimums prescribed, providing the person operating helicopter complies with any route with and or

altitudes prescribed for Helicopter’s by FAA. Being that UAV is of Helicopters standards and operation

a request for exemption to operate at altitude’s not to exceed 200 AGL or not more than 200 ft above

any elevated platform from which take off is necessary to achieved filming. In the event of such

particular flight plan, property owners, filming crews and other personnel would all be briefed as to

safety and conduct procedures during flight. FOB or ATC having jurisdiction in such area would have

notification and briefing as mandated.

14 C.F.R. Sec 91.121 Altimeter Settings

The requirement of PIC is to use altimeter as means to navigate aircraft to cruise altitudes to and from

corresponding airports as predetermined in flight plan, unless ordered otherwise. As the UAS has no

barometric altimeter, but instead uses GPS altitude read out, an exemption would need be applied.

Per a pre flight check list and live flight data monitoring, the altitude of launch site will be

predetermined and therefore calculated into the UAS- GPS indicator before flight.

14 C.F.R. Sec 91.151(a): Fuel Requirements for Flight in VFR Conditions

Fuel requirements for flight. The maximum flight time under ideal conditions is 30 minutes with the

current manufacturers battery pack. The proposed rule under this exemption would require the UAS

to return to its point of launch if its battery reaches less than 25% provides a higher standard of safety

when applied to UAS.

14 C.F.R. Sec 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections

Referring to maintenance, preventive maintenance, and alterations to the UAS. The operator will

provide minor maintenance and inspection to the UAS, documented as outlined in the operational

and safety guidelines. Given the size and simplicity of the UAS combined with the operational and

safety guidelines outlined in this petition the operator can maintain or exceed the required level of

safety.
I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety.

Please contact me at any time if you require additional information or clarifications on this request. 

Sincerely,

Jason Haab

Phone: (309) 862-4324

Email: jason@haabair.com

Appendix A: Pilot's License

Appendix B: QAV500 Build Manual