Sean Lehew

29052 Pelican Dr Punta Gorda FL, 33982 seanlehew@gmail.com 941

- 628

- 1157 U.S. Department of T ransportation Dock et Management System 1200 New Jersey Ave., SE Wa shington DC 20590

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act ”) and 14 CFR Part 11, Sean Lehew , operator of an Unmanned Aircr aft System (UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its UA S, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in the following manner: Aerial photography and/or video f or public and/or private use including real estate, architecture, land surveying, engineering and other related prof essional activities. Aerial inspection/photogr aphy of residential/commercial structures under contr act with the owners or local government authority

. Aerial inspection/photogr aphy of residential/commercial utility infrastructure including but not limited to electrical power lines, w ind turbines and cell towers. Aerial video/photography or providing live video f eed to assist with search and rescue operations in cases of an emergency or natural disaster only when the local authorities or government has requested it by contr act or donat ion. The ability to off er training to persons individually or belonging to both private and/or public organizations that have interests in the use and application of a UAS for the purpose of the saf e operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the persons and property

. As described fully below , the requested exemption would permit the operation of a U AS under controlled conditions in the NAS that would be a) limited b) controlled c) predete rmined and d) will pr ovide safety enhancements to the already saf e operations in the industry presently using conventional aircr aft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of T ra nsportation’ s (the FAA Administrat or ’s ) responsibilities to “....establish requirements fo r the saf e operation of such aircr aft s ystems in the national airspace system. ”The name and address of the applicant is:



### Sean	Lehew 29052	Pelican	Dr. Punta	Gorda	FL	33982

Sean Lehew will operate the Yu neek Q

- 500 ,

Q500 TYPHOON Aircraft Flight Time Up to 25 Minutes Height 240mm (9.45 in) Width 420mm (16.54 in) Diagonal Length Without Rotor Blades 565mm (22.2 in) Propeller/Main Rotor Diameter 330mm (13.0 in) Weight Without Battery and Payload 1130g (40.0 oz) Battery 5400mAh 3S 11.1V LiPo (included) Charger 3S 11.1V LiPo DC Balancing Smart Charger with AC Adapter (included) Transmitter 10

- channel 2.4GHz with 5.8GHz video downlink (included) 3 Flight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet Above Ground Level (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 CGO2

- GB 1700g (60.0 oz) Radio Control Frequency Band 2.4GHz CGO2

- GB Camera Gimbal System Focusing System A erial Optimized Fixed Focus Video Resolution FULL HD 1080p

- Adjustable 6 0, 50 or 48 FPS Photo Resolution 12 Megapixels Video Field of View 130° Control Angle Accuracy ±0.02° White Balance Automatic Smart White Balance Feature Transmission Band 5.8GHz Input/Operating Voltage 7.0V to 14.0V DC Video Transmission Di stance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) with ST10 Warning: You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times. Current Consumption/Operating Current 500mA (average) to 600mA (peak) @ 12.0V (7.2W max) Storage Temperature

- 20°C

- 60°C Working Temperature 0°C

- 50°C Storage (memory) microSD Class 10 ~ 4 to 128GB Height 115mm (4.5 in) Weight 185g (6.5 oz) Depth 135mm (1.4 in) Width 74mm (2.9 in) ST10 Personal Ground Station Operating System AndroidTM Number of Channels 10 Control Transmission Distance/Range (Optimum Conditions) FCC Com pliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft)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 La ws and Maintain Visual Line of Sight of Aircraft at All Times. Flight Systems Tel emetry 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

Given the small size of the U AS and the controlled environment provided the proposed operations will adhere to the Reform Act ’s safety requirements. The approv al of this application presents no national security issues. Reg arding the level of saf ety surrounding the proposed oper ations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the gr ant of the requested exemption is in the public interest. Accordingly the applicant requests that the FAA gr ant the requested exemption wit h minimum dela y.

**AIRCRAFT AND EQUIV**

**ALENT LEVEL OF SAFETY** The operation limitations proposed for an equiv alent or higher level of saf ety because operations will further enhance the saf ety of the persons and/or property using conventional aircr aft. These li mitations 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 (FOM) include: The U AS will weigh less than 55 lbs. The U AS will have a ma ximum operating speed of no more than 50mph. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). Maximum flight time f or each operational flight will be 30 minutes. Flights will be terminated at25% bat tery power reserve or 30 minutes of flight time whichever occurs first. Flights will be operated at an altitude of no more than 400 f eet Above Ground Level (AGL) and not more than 200 f eet above an elevated platform from which filming is planned.
Minimum c rew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator

. A briefing will be perf ormed regarding the planned UAS operations prior to each da y’ s flight consisting of all the days’ pr oduction activities. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only

. The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Po int (ARP) of a tower controlled or uncontrolled a irport. The operator will obtain verbal/written consent of all persons involved with the planned oper ation and ensure that only consenting persons will be allowed within 100 f eet of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of saf ety determination, as required under the FOM. With the adv anced permission of the FSDO, operations at closer r ange may be approved. The PIC and VO will have been tr ained in operation of U AS and receive up

- to
- date information for the particular U AS 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 enf o rcement, fire or other appropriate governmental agencies. If the U AS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre

- determined location within a designated location and land autonomo usly

. The U AS will have the capability to abort a flight in case of unpredicted obstacles, weather , or emergencies.
**14 C.F .R. P**  **art 21, Subpart H: Airworthiness Certificates 14 C.F .R. §91.203 (a) (1)**  Subpart H, entitled Airworthiness Certificates, establis hes the procedur al requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the siz e and limited oper ating area associated with the aircr aft to be utilized by the Applicant, an exemption from Part 21 Subpart H m eets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to ex empt aircr aft from the requirement f or an a irworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that theUA S oper ated without an airworthiness certificate, in the restricted environment and under the

conditions proposed will be at least as saf e, or safer , than a conventional aircr aft (fix ed wing or rotorcr aft) operating with an airworthiness certificate without the restrictions and conditions pr oposed. The U AS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger

, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlik e other civil aircr aft, operations under this e xemption will be tightly controlled and monitored by both the operator and under the requirements and in compliance with local public saf ety requirements. The FAA will have advance notice of all operations. The se saf ety enhancements provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H. Lastly

, application of these same criteria demonst rates that there is no credible threat to national security posed by the U AS, due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.
**14 C.F .R.**  **§ 45.23 (b). Marking of the Aircraft** The regulation requires: When marks include only the Roman capital letter "N" and the regis tr ation number is displa yed on limited, restricted or light

- sport category aircr aft or experimental or provisionally certificated aircr aft, the operator must also display on that aircr aft ne ar each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport," "e xperimental," or "provisional," as applicable. Even though the UAS will have no ai rworthiness certificate, an exemption may be needed as the UAS will have no entr ance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the UAS, two

- inch lettering will be impossible. The word “Experime ntal” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the UAS mark ed on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the U AS will see the i dentification of the U AS as “Experimental. ”
**14 C.F .R. §91.7(a): Civil Aircr**  **aft Airworthiness.** The regulation requires that no person may oper ate a civil aircr aft unless it is in airworthy condition. As there will be no airworthiness certificate issued f or the aircraft, should this exemption be granted, no FAA regulatory standard will exis t for determining airworthiness. Given the size of the aircr aft for maintenance and use of saf ety check lis ts prior to each flight an equivalent level of safety will be pr ovided.

**14 C.F .R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircr**  **aft.** Section 91.9 (b) (2) provides: No person ma y operate a U.S.

- registered civil aircr aft ... (2) For which anAirplane or Rotorcr aft Flight Manual is not required by §21.5 of this chapter , unless there is available in the aircr aft a current approved airplane or Rotorcr aft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The U AS, given its size and configuration has no ability or pla ce to carry such a flight manual on the aircr aft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircr aft. The equiv alent level of saf ety will be maintained by k eeping the flight manual at the ground control point where the pilot flying the U AS will have immediate access to it.
**14 C.F .R. § 91.103: Preflight Action.**  This regulation requires each pilot in command to tak e certain actions before flight to insure the saf ety of flight. As FAA a pproved rotorcr aft flight manuals will not be provided f or the aircr aft an exemption will be needed. The PIC will tak e all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather , flight battery requ irements, landing and tak eoff distances and aircr aft performance data before initiation of flight.
**14 C.F .R. §91.109: Flight Instruction.**  Section 91.103 provides that no person ma y operate a civil aircr aft (except a manned free balloon) tha t is being use d for flight instruction unless that aircr aft has fully functioning dual controls. UAS and remotely piloted aircr aft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communica tes with the aircr aft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircr aft. The equivalent level of saf ety provide d by the f act that neither a pilot nor passengers will be carried in the aircr aft and by the size and speed of the aircr aft.
**14 C.F .R. §91.119: Minimum Safe Altitudes.**  Section 91.119 establishes saf e altitudes f or operation of civil aircraft. Section 91. 119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed f or helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the e xemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platf orm from which filming is planned, an e xemption ma y be needed to allow such operations. As set f orth herein, the U AS will never operate at higher than 400 AGL with the e xception that in circumstances where the UAS is used to survey or photogr aph a structure whose height e xceeds 400 feet AGL, the UAS will not be operated more than 200 f eet above the highest point on the structure. It will howe ver be operated in a restricted area with security perimeter , where buildings and people will not be exposed to operations without their pre

- obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be tak en without the permission of the property owner or local officials. Because of the adv ance notice to the property owner and participants in the filming activity , all aff ected individuals will be a ware of the planned flight operations. Compared to flight oper ations with aircr aft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is f ar less than thosepre sently presented with conventional aircraft operating at or below 500 AGL. In addition, the low

altitude operations of the U AS will ensure separation between these UAS operations and the oper ations of conventional aircr aft that must comply with Section 91. 119.
**14 C.F .R. §91.121 Altimeter Settings.**  This regulation requires each person operating an aircr aft to maintain cruising altitude by ref erence to an altimeter that is set “

... to the elevation of the departure airport or an appropriate altimeter setting available before departure. ” As the U AS may not have a barometric altimeter , but instead a GPS altitude read out, an e xe mption may be needed. An equivalent level of saf ety will be achieved by the operator

, pursuant to the safety check list and live flight da ta monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator be fo re flight.
**14 C.F .R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions**  Section 91.151 (a) prohibits an individual from beginning “a flight in a n airplane under VFR conditions unless (considering wind and f orecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day , t o fly after that f or at least 30 minute s; or (2) At night, to fly after that for at least 45 minutes. ” The battery powering the UAS provides approximately 30 minutes of powered flight. T o meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to appro ximately 10 minutes in length. Given the limitations on the UAS’ s proposed flight area and the location of its pr oposed operations within a predetermined area, a longer time frame f or flight in daylight or twilight VFR conditions is reasonable. Applicant believes th at an e xe mption from 14 CFR §91.151(a) f alls within the scope of prior exemptions. Operating the UAS, in a tightly controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Additionally, limiting U AS flights to 10 minutes would greatly reduce the utility for which the e xempt ion will be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power

— whichever happens first. This restriction would be more than adequate to return the UAS to its planned lan ding z one from anywhere in its limited operating area.
**14 C.F .R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.**  These regulations require that an aircr aft operator or owner “shall have that aircr aft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in par agr aph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ..., ” and others shall inspect or maintain the aircr aft in compliance with Part 43. Given that these section and Part 43 apply only to aircr aft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the oper ator pursuant to the flight manual and operating hand book. An equivalent level of saf ety will be achieved because the U AS is very limited in siz e and will carry a small pa yload and operate only in restricted areas for alimited period of time. If mechanical issues arise the U AS can land immediately and will be operating

from no higher than 400 f eet AGL. The operator will ensure that the UAS is in working order prior to initiating flight, perf orm required maintenance, and k eep a log of an y maintenance perf ormed. Moreover

, the operator is the person most f amili ar with the aircr aft and best suited to maintain the aircr aft in an airworthy condition to provide the equivalent level of saf ety
. An equiv alent level of saf ety will be achieved because maintenance and inspections will be performed in acc or dance with the UA S Manuf acturer's User Manual. As provided in the FOM, the oper ator will ensure that the UAS is in working order prior to initiating flight and perf orm required maintenance needed. Sincerely , 

### Sean Lehew