September 7, 2015

U.S. Department ofTransportation Docket Management System 800 Independence Ave. SW Washington, DC 20591

Re: Section 333 ofthe FAA ReformAct of2012 Public DocketNo. FAA-2015-0968

DearAdministrator, ·'"! 'l i v, (

I, James J. Johnson dba Crescent City Aerial Services , herein referred to as (the petitioner), am writing pursuant to the FAAModernization and Reform Act of2012 and theprocedures contained within 14 C.P.R. 11, to request granting ofan exemption from the Federal Aviation Regulations listed below and anyregulation as required by the FAAthat is deemed necessary in orderto conduct commercial UAS operations as described.

The requested exemption would permit the petitioner to pursue, safe, professional, for profit services to private and public entities within the State ofLouisiana and adjoining states, utilizing

a smallunmanned aircraft system (sUAS) for aerial still and video data capture and thermal imaging for, butnot limited to the following purpose:
1. Real Estate Sales 2. Residential/Commercial Roofinspections/Flare Stack inspections 2. Precision agriculture 4. Surveying and mapping 5. Civil infrastructure/bridge and roadway inspection 6. Construction 7. Process, power, and utilities inspections 8. Law enforcement, security, and emergency response 9. Television and Motion Picture Cinematography 10. Property/Environmental Video Survey 11. PhotoNideography ofcontracted outdoorrecreational activities onprivate and public use lands (Prior Permission and coordination Only)

The safe integration ofthe UAS into the national airspace without interference orhazard to manned aircraft is ofutmost importance. The proposed services are offered withthe intent of enhancing the development and safe operation ofunmanned aircraft systems, realizing that current manned aircraft operations pose a much greaterrisk ofpersonal injury and or death and extensive propertydamage. The use ofUAS would fulfill a service to consumers and small entities that would otherwise not exist dueto the risks and costs involved with manned aircraft.
The initial (sUAS) to be utilized during the operations is a consumer class helicopter, quad-rotor aircraft. It is manufactured byYuneec, Inc. and has the manufactures model designation Q50+ Typhoon. It is an advanced (sUAS) with state ofthe art safety features, GPS lock, altitude,\



### position hold stabilization, smart mode, angle mode follow me and return to home mode. The ground stationhas telemetry with altitude, groundspeed, 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 personview onthe controller that is not to beused for flight bythe PIC. The UAS has the ability to link with a smartphone ortablet for video link separate from the on-board display ifneeded. The UAS has separate radio frequencies for telemetry and video downlink and aircraft control. Seethe following manufactures specifications.

Yuneec 

### 0500+ Typhoon, quad copter Flight Time Up to 25 Minutes Height 240mm (9.45 in) Width 420mm (16.54 in) Diagonal Length W\0 Rotor Blades 565mm (22.2 in) Propeller/Main Rotor Diameter 330mm (13.0 in) Weight W/0 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 AGL (Adjustable viathe Q500 GUI) Maximum Rotational Velocity 65°/s Maximum Bank Angle 35° Maximum Climb Rate in Smart and Angle mode 3rnls Maximum Descent Rate in Smart and Angle mode 2rnls TakeoffWeight with Battery and CG02-GB 1700g (60.0 oz)

Radio Control Frequency Band 2.4GHz Maximum Groundspeed 15 MPH
STlO Personal Ground Station Operating SystemAndroidTM Number ofChannels 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: Upto 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) Warning: You Must Follow Local Laws and Maintain Visual Line ofSight ofAircraft 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 BatteryVoltage 

### I Capacity 3.6V/5200mAh 18.72Wh

# ..........___________

CG02-GB Camera Gimbal System Focusing SystemAerial Optimized Fixed Focus Video Field ofView 130° Transmission Band 5.8GHz Video TransmissionDistance/Range FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) with STl0

UAS's are often seen as superior to manned helicopters dueto the smaller size and lower costs, reduced noise and as such, a much smaller environmental and safety impact.
Thepetitioner requests exemption to operate a Yuneec, Q500+ Typhoon equipped with a threeaxis CG02 Gimbal and Camera, bothproducts ofYuneec. 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 of300 feet from the controller. These limits are preset atthe factory and will be kept at those limits, which currently complywith the AMA's and FAArequirement for Visual Line ofSight limitation and an AGL limitation. The ground station is also programmed with a safety feature that disables motor start up ifwithin Class B, and C airspace boundaries. The Q500 also has the failsafe-automated feature ofreturn to home inthe event that communication is lost between the ground station and the aircraft.

In addition to therequirements already set forth by C.P.R. Title 14 and the applicable FAR, The petitioner will-- 1. Onlyoperate its UAS in direct visual line ofsight ofthe pilot and/or observer without

use ofa visual aid other than corrective lenses. 2. Operate at an altitude no greaterthan 400 feet above the ground. 3. Operate with due vigilance and knownpracticed see and avoid scanning techniques to avoid any conflicts with manned orother UAS aircraft that may enterthe UAS operating area. The UAS flight will be immediatelyterminated ifa potential conflict may exist. 4. Operateoverprivateorpublic sites only with priorpermission from propertyowner
orowner's agent or legal authorities as allowed by law. 5. Terminate flight when anyunsafe condition exists. 6. Terminate flight whenbattery voltage drops to 15% ofbattery capacityorwhen the t • 1s low battery alert occurs perthe Q500 Typhoon Instruction Manual, not to exceed 18 minutes run time. 7. Operate at a ground speed ofO to 50 knots during on site missions. 8. Operate in accordance with the guidance and standards set forth bythe AMA, the UAS manufacturer and the administrator. 9. Operate with a minimum crew for each operation consisting ofthePIC and a visual observer, ifneeded, in direct communication utilizing appropriate verbal, radio or cell phone. 10. Provide ground instruction with standards and content currently accepted bythe administrator for private pilot knowledge testing, to the observer and or UAS.


### 14 CFRPart 21, Subpart H: Airworthiness Certificates This part

### ~stablishes the procedures for the issuance ofan airworthiness certificate. While the

.FAA contmues to workto develop airworthiness standards for sUAS, we request anexperimental certificate be issued for the sUAS's operated bythe applicant under either orboth ofthe following provisions:

21 .191 Experimental certificates. Experimental certificates are issued for the following purposes:
(a) Research and development. Testing new aircraft design concepts, new aircraft equipment,

new aircraft installations, new aircraft operating techniques, or new uses for aircraft.
(b) Showing compliance withregulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance oftype and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance withthe function and reliabilityrequirements ofthe regulations.

Since the experimental certificate can be used for commercialpurposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well.

The aircraft will not carrypersons orproperty and will only fly under strict operational requirements. Combined with the fact that any aircraft operated would be light weight we proposethat a sUAS will be at least as safe, ifnot safer, than a conventionally certificated aircraft performing the same function.

Ifan experimental airworthiness certificate is not appropriate for this application, then we request an exemption ofl4 CFR Part21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafety outlined in the previous paragraph.

14 CFR45.23 Display ofmarks; general and 45.29 Size ofmarks. These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must display the word

1 "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit,**~r** pilot station. A sUAS does not have an entrance in whichthe word "EXPERIMENTAL" canbe placed, and may not have a registration number assigned toit bythe FAA. If 14 CFR 45.23
f Displayofmarks general and 45.29 Size ofmarks is not appropriate for this application, the* we request an exemption of14 CFR 45.23 and 14 CFR 45.29 andthe requirement for Display of marks and size ofmarks. To obtain an equivalent level ofsafety and meet the intent of45.23j and 45.29, we propose that markings deemed appropriate for this aircraft bythe FAA will**locate~** withthe crew at the ground control station and available for inspectionuponrequest. 1

! I The petitionerrequests exemptionfrom 14 CFRpart 61.113 Private Pilot Privileges,**Pi~ot** 

### in Command Section (a). An exemption is requestedbecause no PIC willbe allowed to**op~rate** the sUAS unless that PIC has met certain**~ight-hour curren~y** **requ~ements, de~onstrating**  ,hat the PIC is able to safely operatethe sUAS m a manner consistent With the operations and

. specifications as described in this exemption, including evasive and emergencymaneuvers, 

# b
well as maintaining appropriate distances from people, vessels, vehicles and structures.

## Fu~her, the petitioner submits that all flights ofthe sUAS, conducted bythe PIC pursuant to the grll4t of

I

# ..

this petition: (1) will be incidentalto thebusiness ofViewsAbove; and (2) willnot carry passengers for compensation orhire.

Title 14 CFRpart 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness Certificate is available for this sUAS thepetitioner requests exemptionunder this part utilizing a preflight inspection and the manufacturer's documents for determining compliance ofthe sUAS airworthiness. Thepetitioner warrants compliance to part 91.7(b) in that the operation will only be conducted after a thorough preflight and pre-mission planning inspection is completed, to include current and forecast weather, airspace, notams (notice to airmen), area ofoperations, and notice issued to non-participating persons in local proximity. The petitioner will utilize the Yuneec, QSOO Instruction manual, quick start guide and the petitioners ownpre-flight checklist to determine the sUAS airworthiness.

14 CFR91.9 Civil aircraft flight manual, marking, and placard requirements.This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. The intent ofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the sUAS cannot carry such a manual, and ifthe sUAS did carry such manual, it would be unavailable tothe crew for review. To obtain an equivalent level ofsafety and meet the intent of91.9, weproposethat a current, sUAS manufacturers operation manual or equivalent be available to the crew at the ground station anytime the aircraft is in, orpreparing for flight.
14 CFR. 91.103: Preflight Action. This petition seeks an exemption from 91.103, whichrequires a PICto become familiar with specific informationbefore each flight, including information contained in the FAA approved Flight Manual onboard the aircraft.22 Inasmuch as an FAA approved flight manual will notbe provided for the sUAS, an exemption is requested. An equivalent level ofsafetywill beprovided by following the manufactures operations manuals comprehensive preflight checklist. The PIC willtake all actions, including reviewing weather, flight batteryrequirements, landing and takeoffdistances, and aircraft performance data, before initiation offlight.

14 CFR91.109 Flight instruction; Simulated instrument flight and certain flight tests. Theregulationprovides that "No personmay operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The controls for a sUAS do not currently have a set offully functioning dual controls. Ifa sUAS pilot is being trained, the pilot performing the training would be directly supervising and could take overthe controls from thepilot intraining ifthe need arose. This would be similar to the technique ofa "throw-over type" control wheel in some fixed wing aircraft. We feel that this technique meets the intent 91 .109 and provides an equivalent level ofsafety.

The petitioner requests exemption from 14 CFRpart 91.119(c) Minimum Safe Altitudes. Thepetitioner requests exemption from Section (c) withthe following conditions and limitations. Thepetitioner requests the exemption due to the scope ofthe operations to beperformed and the requirement to operatebelow 400 feet AGL. The Petitioners primary mission would be to record dataor survey ofpersons, property or structures as listed above. The sUAS size, weight, speedand limited operating times and area, as well as the soft materials used inthe construction ofthe sUAS, would provide an equivalent or greater level ofsafety as intended under this part.
The Q500+ is a helicopter as definedby CFR Title 14, FAR Part 1, general defmitions. The sUAS has a vertical to near vertical descent in the event ofa power failure. Fly-a-ways wouldbe the greatest or most dangerous risk to non-participating persons. The Q500 has no documented (fly-away), while operated under GPS lock within the parameters ofthe Q500 operating instructions. The Q500+ is a very stable, low rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized UAS. In an emergencythe sUAS would be quickly brought downperthe loss ofcontrolprocedure as described in the emergencyprocedures checklist, adequatetime to completethe procedure would exist due to the 0 to 15 mph operational groundspeed ofthe Q500. The risk to persons 100 feet awaywould be at no greater risk than persons located 500 feet away. The petitionerrequests exemption from the 500-foot altitude restriction and the 500-foot standoffrestriction from persons, property orvessel applied
to previous grants ofexemptions. The exemption is requested withthe following conditions and limitations in conducting the petitioners operations1. The sUAS will be operated at an altitude ofno more than 400 feet above ground level without receiving a COA. 2. The sUAS will not be operated at greater than a 500-foot slant distance from the PIC. 3. The sUAS will not be operated over a non-participating property, structure orvessel without priorpermission from the property owneror legal representative. 4. The sUAS will maintain a minimum slant distance of100 feet fromany nonparticipating person and will increase the distance proportionallyby 50 ft. per 50 ft. ofaltitude. At no time will the sUAS be operated closer than a 1 00-foot slant distance to a non-participating person unless that person is behind a protective barrier or shielded from possible debris in the event ofa crash.

The petitioner requests exemption from 14 CFRPart 91.121, Altimeter settings. The UAS will not have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within VLOS and at orbelow 200 feet AGL, combined with the petitioner's intention to limit the altitude ofthe UAS through flight limit function onthe UAS, has beenpreviouslyruled to be a sufficient method for ensuring the UAS operations do not adversely affect safety. The altitude information willbe 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 CFRPart 91.151, Fuel requirements for flight 

### in VFR conditions, priorreliefhas been granted for manned aircraft to operate at less thanthe prescribed minimums, including ExemptionNos. 2689, 5745, and 10650. In addition, similar VAS-specific reliefhas been granted an ExemptionNos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR) conditions. The petitioner's UAS provides low batterywarnings that indicate the PIC must command the UA's returnto the launchpoint when lowbatterycapacity voltage is reached. The UAS also provides 2 and 3rdincreased intensity critical low battery warnings through audio and vibration indicating that the UA must be landed immediately, additionally a failsafe automatic landing will occurwhenthe batteryis at absolute critical lowvoltage. The petitioner warrants that the sUAS will be landed immediatelyupon the 1stlow battery alert orno longer than 18 minutes whichever occurs first. The petitioner will not initiate a flight unless (considering wind and forecast weather conditions) there is enoughpowerto fly at normal cruising speed to the intended landing point and land the UAwith 30%batterypower remaining.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that

an airworthiness certificate, withthe registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificatebe "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." A sUAS is too small to carry documentation, does not have an entrance, and is not capable ofcarrying passengers orcrew. To obtain an equivalent level ofsafety and meet the intent of91.203, wepropose that documents deemed appropriate for this aircraft bythe FAAwill be co-located with the crew at the ground control station and available for inspection uponrequest.

The petitioner requests exemption from 14 CFR Subpart 

### E (§§ 91.401-417),) Maintenance required, 91.407(a)(l) Operation after maintenance, preventive maintenance, rebuilding,
or alteration, 91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records. Currentlythe manufacturer's maintenance procedures govern preflight with no limits otherthan

one condition. The petitionerwill complete all authorized component replacements at the petitioner's base ofoperations orin the field as required. The manufacturer or authorized repair center will complete any maintenance orrepairs that cannot be completed bythe petitioner. The· petitioner warrants that preflight, post flight and maintenance procedures should provide an acceptable level ofsafety for the operations perfonned and is consistent with those ofprevious grants. In addition the petitioner will complywith any and all manufacturers updates for UAS and Ground station as well as any FAA directives and guidelines. An appropriate aircraft/maintenance logbook will bekept with the sUAS ground station and base ofoperations.

Summary
Granting the present Petition will further the public interest by allowing the petitioner to safely, efficiently, and economically perform aerial video and photography ofreal estate, environmental sites, and outdoorrecreational facilities. Additionally, the use ofthe Yuneec Q500 UAS will decrease congestion ofthe NAS, reduce pollution, and provide significant benefits to the economy.

1. The Public Will Benefit From Decreased Congestion OfThe NAS.
The Yuneec Q500 is batterypowered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. Byreducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa Yuneec Q500 UAS would reduce the amount ofmanned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety oflife and property inthe air and onthe ground.Furthermore, byreducing the number ofmanned aircraft operating inthe NAS, congestion around airports caused by arriving and departing aircraft will bereduced. The UAS does not require an airport to takeoffor land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraft that mustbe handled by air traffic control.



### 2. The PublicWill Benefit From the Safety and Efficiency ofthe Yuneec QSOO 

### UAS Conducting aerial acquisitions withthe Q500 instead ofmanned aircraft, will greatly benefit the public by drasticallyreducing the levels ofair and noise pollution generated during traditional aerial video and stillphotography flight operations. Byusing batterypower and electric motors, the Q500 UAS produces no air pollution, and is themost viable environmentally conscious alternative to the cabinclass, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, while burning approximately 20-30 gallons perhour ofleaded aviation fuel. The Yuneec Q500 Typhoon, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, as the UAs are propelled bybatterypowered electric motors, rather than an internal combustion engine.
Byusing the Q500 UAS to perform aerial acquisitions, the substantialriskto life and property inthe air and onthe ground, which is usually associated with traditional manned aircraft flight operations, will be substantiallyreduced or completely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the Q500has. less physicalpotential for collateral damage to life and property onthe ground, and inthe air, compared to the manned aircraft that typically conduct similar operations.



### 3. PerformingAerial Video and Photography Operations With The Yuneec QSOO 

### UAS Will BenefitThe Economy.

In additionto being safe and efficient, the Q500 UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation ofthe Q500 will allow United States based companies, like ViewsAbove, to remain competitive and contribute to growth of the U.S. economy. Specifically, withthe rising cost ofaviation fuel and the Environmental Protection Agency ("EPA") 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 Q500 UAS is one suchtechnology that not only allows companies greater operational flexibility compared to manned aircraft, butprovides such flexibility without the high operational cost ofa traditional manned aircraft.
Byoperating the Q500 UAS, companies such as ViewsAbove, canremain competitive and profitable, and therefore, provide greaterjob stability to employees and contractors, whichwill ultimately contribute to growth ofthe U.S. economy. Improved financial performance ofU.S. companies, through commercialuse ofthe Q500 UAS provides a stable workforce that increases

consumer spending; improves local, state, and federal tax revenues; and allows companies to invest inresearch and development in order to remain competitiveboth inthe United States and abroad.



### 4. ThereAre No Privacy Issues.

Similarto themanned aerial acquisition flight operations thathavebeenconducted for decades, the petitioner's proposed operation ofthe Q500 UAS willnot implicate anyprivacy issues. Specifically, the Q500 UAS will be operated only incompliance with operating documents and procedures whichrequires property owner involvement as well as local law enforcement notification, and in accordance withthe Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. §

Please contact the petitioner with any questions