December,16 2015

Attn:
U.S. Department of Transportation Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Ave, SE Washington, DC 20590

Request an exemption from the requirements of title 14 of the code of Federal Regulations Sections:
91.7(a),91.121,91.151(b),91.405(a),91.407(a)(1),91.409(a)(1)&(a)(2), and 91.417(a)&(b) concerning commercial operation of a Yuneec QS500 Typhoon unmanned aircraft systems pursuant to section 333 of the FAA Modernization and Reform Act of 2012 (Pu blic Law 112

-95)

William Corbett Owner and PIC of Yuneec QS500 Typhoon 109 Harmony Street Evans City, PA. 16033 605

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-4674 Traffcon21@gmail.comGLOSSARY OF ABBREVIATIONS

AGL ABOVE GROUND LEVEL AOI AREA OF INTEREST ATC AIR TRAFFIC C ONTROL ATO AIR TRAFFIC ORGANIZATION AV AERIAL VEHICLE CFR CODE OF FEDERAL REGULATIONS COA CERTIFICATE OF AUTHORIZATION FAA FEDERAL AVIATION ADMINISTRATION FAR FEDERAL AVIATION REGULATION GCS GROUND CONTROL SYSTEM GPS GLOBAL POSITIONING SYSTEM LOL LOSS OF LINK NAS NATIONAL AIRSPACE SYSTEM NOTAM NOTICE TO AIRMAN PIC PILOT IN COMMAND SECTION 333 FAA MODERNIZATION AND REFORM ACT OF 2012 (FMRA) SO SAFETY OBSERVER SOP STANDARD OPERATING PROCEDURE UA UNMANNE D AIRCRAFT UAS UNMANNED AIRCRAFT SYSTEM VFR VISUAL FLIGHT RULES VLOS VISUAL LINE OF SIGHT VMC VISUAL METEOROLOGICAL CONDITIONS VTOL VERTICAL TAKEOFF AND LANDINGSUMMARY

I (William Corbett) am seeking exemption from the requireme nts of 14 C.F.R. , 91.7 (a),91.121,91.151(b),91.405(a),91.407(a)(1),91.409(a)(1) & (a)(2), and 91.417(a) &(b), to operate an Unmanned Aircraft System (Yuneec QS500 Typhoon) pursuant to Section 33 of the Faa Modernization and Reform Act of 2012 (FMRA). This exemption will permit myself to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes and events over certain areas of the United States. INTRODUCTION AND INTERESTS OF THE PETITIONER I have worked in the aviation community for the last fourteen years as an Air Traffic Control Specialist, I have also have held my Private Pilot license since 11/05/2000. I am trying to broaden my knowledge into the new and vastly expanding UAS field. I have operated Remote Control Aircraft for the last nine years without incident and have now been operating my UAS for approximately six months recreationally without incident. The objective to my UAS aerial operations is to provide a more affordable, high quality production system for a variety of governmental, commercial, public and residential uses, specifically targeting:

- Construction Sites before and after

-Appraisals

- Real

- estate m arketing

- Economic development

- Civic landmarks

-Special event coverage

- Private and governmental training

- Oil and gas field safety inspections

BACKGROUND Unmanned Aerial Systems: Yuneec QS500 Typhoon I am asking for exemption to operate a Yuneec QS500 Typhoon for compensation or hire within the NAS . The Yuneec QS500 Typhoon is a vertical takeoff and landing (VTOL) Unmanned aircraft (UA) with a Ground Control Station (GCS) utilizing a 2.4 GHz transmitte r. The Yuneec QS500 has a maximum gross takeoff weight of approximately 3 lbs. while having a diagonal dimension of approximately 24”, and a maximum speed of approximately 16’ fps and is geo fenced to an altitude maximum of 400’ agl. The Yuneec QS500 Typho on is equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.The Yuneec QS500 Typhoon will be operated by myself and will be registered in accordance with

49 U.S.C. 44103, Regristration of Aircraft, as wel l as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

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BASIS FOR PETITION Petitioner, William Corbett, Pursuant to the provisions of the Federal Aviation Regulations (14 C.F .R. 11.61) and the FMRA Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate my Yuneec QS500 Typhoon, UAS in the NAS and for exemption from the requirements of 14 C.F.R.,91.7(a), 91.12 1, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &(b). In consideration of the speed, weight, size and limited operating area associated with the unmanned aircraft and its operation, My operation of the Yuneec QS500 Typhoon UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, I request relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1)&(a)(2), and 91.417(a)&( b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. I submit that the requested relief is proper since an equivalent level of safety will be ensured. I will use experienced personnel o r technicians to perform maintenance, or preventive maintenance on the UAS using the methods, techniques and practices prescribed in the operating documents (ie., Monthly Maintenance Log, And Yuneec QS500 Typhoon Instruction manual). Furthermore I will doc ument and maintain all maintenance records for the UAS. I am also seeking relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the Yuneec QS500 Typhoon UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, I submit that I will ensure that the Yuneec QS500 Typhoon is in an airworthy condition, prior to every flight, by determining that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and the Yuneec QS500 Typhoon Instruction manual), and that the aircraft is in a condition for safe flight.I also seek an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the

Yuneec QS500 Typhoon does not have a typical baro metric altimeter on board. However, altitude information from the UAS will be provided to the PIC via GPS equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with my operation of the Yuneec QS500 Typhoon UAS within visual line of sight, at or below 400’ AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, I seek exemption from the requirements of Section 91.151(b ), entitled Fuel requirements for flight in VFR conditions. I submit that safety will not be affected by operation of the Yuneec QS500 Typhoon UAS during daylight hours in VMC conditions under visual flight rules, with enough battery power to fly for a tot al duration of approximately 25 minutes. Battery power indicators are also able to show exactly how much battery power is left, as well as how much time is needed to return safely back to the take off point. In accordance with 14 C.F.R. 11.81 I provide the following information in support of its petition for exemption: A. Name and Address of The Petitioner The name and address of the Petitioner and point of contact is: William Corbett 109 Harmony Street Evans City PA. 16033 605

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-4674 Traffcon21@gmail.comB. The Specific Sections OF 14 C.F.R. from which I seek exemption.

1. I seek exemption from the Requirement Of Section 91.7(a) Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition 2. I seek exemption from the Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

– (i) The curre nt reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate ava ilable station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. 3. I seek the exemption from the requirement of Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the fi rst point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 4. I seek exemption from the requirement of section 91.405(a). Section 91.405, entitled Maintena n ce required, subsection (a), states the following : Each owner or operator of an aircraft

- (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter.5. I seek exemption from the requirements of section 91.407(a)(1) Section 91.407 entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

- (1) It has been approved for return to service by a person authorized under 43.7 of this chapter. 6. I seek exemption from the requirements of section 91.409(a)(1) and 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

- (1) An annual ins pection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. 7. I s eek exemption from the requirements of sections 91.417(a) and 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: (a) Except for work performed in accordance with 91.411 and 91.413, each registered owner or op erator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspecti ons, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

- (i) A description ( or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service.(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specific time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and s afety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers and appliances (b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. **C. The extent of relief I seek and the r** **easons I seek the relief. 1.**  **Extent of relief I seek and the reason I seek relief from Section 91.7(a)** Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow myself to determine that the UAS is in airwo rthy condition prior to every flight by ensuring the UAS is in compliance with the operating documents. (i.e., Monthly maintenance log, and Yuneec Instruction manual)I reque st the relief because the Yuneec QS500 Typhoon UAS do not require an airwort hiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, I will ensure the UAS is in airworthy conditions based upon its compliance with operating documents prior to every flight, and further, determine that the aircraft are in condit ion for safe flight, as stated in the conditions and limitations below. **2. Extent of relief I seek and the reason I seek relief from Section 91.121.**  Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the Yun eec QS500 Typhoon, which utilize barometric pressure sensor, GPS equipment and radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station. Since the FAA requires that any altitude informat ion concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), I seek relief because the Yuneec QS500 Typhoon UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure of filed altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought ato the extent necessary to comply with the applicable conditions and limitations sated below. As more fully set forth herei n, an equivalent level of safety will be maintained since the Yuneec QS500 Typhoon is equipped with a barometric sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provid es the PIC with altitude information of the UA on the heads

- up display of the GCS. **3. Extent of relief I seek and the reason I seek relief from Section 91.151(b)**  Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered UAS during daylight hours in VMC conditions, under visual flight rules, for a total duration of 25 minutes. I seek the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered UAS will severely constrain the practicality of any aerial video or still photo flight operations that I propose to conduct pursuant to the petition. Significantly, as set forth below, the technical specifications of the Yuneec QS500 Typhoon UAS, the Yuneec QS500 Typhoon operating documents, an my proposed operating limitations, ensure that I will safely operate the battery powered UAS during daylight h ours in VMC , and under VFR conditions, with enough battery power to fly for a total duration of 25 minutes.**4. Extent of relief I seek**  **and the reason I seek relief from Sections 91.405(a),**

**91.407(a)(1),91.409(a)(1)&(a)(2),And 91.417(a)&(b).** Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, I request relief from these sections because the Yuneec QS500 Typhoon UAS do not require airworthiness certificates. As s et forth more fully below, The Yuneec QS500 Typhoon UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, I will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating documents. Furthermore, I will document and maintain all maintenance records for the UAS. **D. The reasons why granting my request would be in the Public interest;**  **That is , How it would**  **benefit the public as a whole.** Granting the present petition will further the public interest by allowing myself to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, events and civi c landscape over certain areas of the United States. Additionally, Use of the UAS will decrease congestion of the NAS, reduce pollution, reduce noise complaints, and provide significant benefits to the economy. Notably, the benefits of my proposed operatio n of the UAS will be realized without implicating any privacy issues. 1. **The public will benefit from decreased congestion of the NAS**
**.** The Yuneec UAS are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as we ll as increase the safety of life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The UAS do not require an airport takeoff or landing. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, airborne separation, and arrival and landing phases of flight operations. 2. **The public will benefit from the safety and effici ency of the Yuneec QS500 Typhoon.**  Conducting aerial acquisitions with the UAS, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the Yuneec QS500 Typhoon UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder combustion class engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20

-30 gallons per hour of leaded aviation fuel. The Yuneec QS500 Typhoon, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery electric motors, rather than an internal combustion engine.By using the Yuneec QS500 typhoon UAS to perform aeri al acquisitions, the substantial risk to

life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight c rew members on board, the UAS with approximately 3 lb takeoff weight, has less potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations. 3. **Performing aeri al video and photography operations with the Yuneec QS500 Typhoon will benefit**  **the economy.** In addition to being safe and efficient, the UAS are also an economical alternative to using manned aircraft to conduct similar operations, As such, operation of th e UAS will allow United States based companies, like myself, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising costs of aviation fuel and the EPA’s regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered UAS is one such technology that not only allows companies under greater operational flexibility to manned aircraft, but prov ides such flexibility without the high operational costs of a traditional manned aircraft. By operating the UAS, companies such as myself, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, whi ch will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad. 4. **There are no privacy issues.** My proposed operation of the Yuneec QS500 Typhoon will not implicate any privacy issues. Specifically, The UAS will be operated only in compliance with operating documents which require property owner involvement as well as local law enforcement notification, and Air traffic notification if needed, in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 91.119. **E. The reasons why granting the exemption would not adversely affect safety, Or how the**  **exemption would provide a level of safety at least equal to that provided by the rule from**  **which I seek exemption. 1.**  **Reasons why the Yuneec QS500 Typhoon UAS meet the conditions of the FMRA Section 333.** In consideration of the size, weight, speed, and limited operating area associated with the unmanne d aircraft and its operation, My operation of the Yuneec QS500 Typhoon meet the conditions of FMRA section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.Section 333 provides authority for a UAS to operate without an airworthiness certification and

sets for the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following part: (a) In General.

— Notwhithstanding any other requirement of this subtitle, and not later than 180 days after the enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely i n the national airspace system before completion of the plan and rulemaking required by Section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

— in making the determination under subsection (a), the Secretary shall determine, at a minimum

— (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sights do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Cod e, is required for the operation of unmanned aircraft systems identified under paragraph (1) In seeking exemption, I submit that the Yuneec QS500 Typhoon can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the Yuneec QS500 typhoon UAS; (b) the specific operating limitations.

- **A summary that can be Published in a federal register, stating: The rules from which I seek exemption:**  I seek exemption from the requirements of 14 C.F.R. Sections 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)&(a)(2), and 91.417(a) & (b)

- **A brief description of the nature of the exemption that I seek:** This exemption will allow myself to commercially operate an UAS for the purpose of conducting aerial video and photography over certain areas of the United States.**CONCLUSION:**

As set forth herein, I seek exemption pursuant to 14 C.F.R. 11.61 and Section 333 of the FMRA, which will permit safe operation of the Yuneec QS500 Typhoon commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this petition, the FAA Administrator will be fulfilling the Congressi onal mandate of the FMRA, while also advancing the interests of the public, by allowing myself to safely, efficiently, and economically operate the Yuneec QS500 Typhoon commercially within the NAS. **Wherefore,** in accordance with the FAR’s and the FMRA, Sect ion 333, I respectfully resquest that the administrator grant this petition for an exemption from the requirements of 14 C.F.R. Sections 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)&(a)(2) and 91.417(a)&(b), and permit myself to operate a Yuneec QS500 Typhoon UAS commercially for the purpose of conducting aerial video and photography over certain areas of the United States. In closing due to new developments with UAS registration I will be registering my Yuneec QS500 Typhoon on 12/21/15

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Respectfully Submitted, William Corbett 109 Harmony Street Evans City Pa 16033