U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue

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:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, The Rialto Police Department seeks an exemption from Federal Aviation 

Regulations (“FARs”) detailed below for the following described Unmanned Aerial System called 

in this application Yuneec Typhoon and Instanteye MK2 Gen3 which includes an Unmanned 

Ariel System (UAS) and ground station-based equipment and crew:

THE UNMANNED SYSTEM (UAS):

Yuneec Typhoon and Instanteye MK2 Gen3: The inherent safety features, sophistication, 

programmability, GPS navigation, return home capability, airport vicinity no-fly feature and 

restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft 

controller/receiver and for the camera make this a much safer UAS for the purposes of this 

petition. These are radio controlled UAS’s that have the capacity for software upgrades. They 

are light, less than 4 pounds including battery and camera. Incorporated into the programming 

of these UAS’s is an automatic return home feature that automatically directs the craft back to 

point of take off should communication with the transmitter be lost. The Yuneec Typhoon has a

maximum speed of 22 miles/hour. Maximum flight time is 25 minutes. Gross weight is 3.75 

pounds. The Instanteye MK2 Gen3 has a maximum speed of 35 miles/hour. Maximum flight 

time is 30 minutes. Gross weight is under 2 pounds. 

Both UAV’s have an additional communication link between the camera and craft on a different 

remote frequency, allowing the operator or Pilot In Command (PIC) to monitor battery level, 

altitude (AGL), distance from PIC, camera imagery, and control camera angle. The software for 

both UAS’s allows the operator or PIC to set maximum altitude AGL for each flight, allowing 

customization of flights to no higher than 150 feet can be programmed into the UAS's software 

pre-flight to insure compliance with FAA standards, adding to the safety capabilities of these

UAS’s. These UAS’s are programmed to remain in position when controls are released, 

maintaining altitude and GPS location.

Both UAS’s have an altitude and radar monitoring function that allows the operator more precise 

determination of height, direction of flight and distance from the operator (PIC). The operator or 

PIC can monitor GPS lock status while UAS is in flight, with the ability to anticipate loss of GPS 

locking so the operator or PIC can land the UAV as a precaution. Both UAS’s are also equipped 

with a safe dynamic return to home function and automatic safe landing and taking off modes. 

The intelligent battery also calculates how much power is needed to safely return home.

The requested exemption would support an application for a commercial Certificate of 

Authorization to use the above described CAV System to support aerial photography and 

videography.
The UAS’s, powered by batteries, are smaller, lighter and more maneuverable than larger

aircraft running on combustible fuel, they operate at lower altitudes with no people on board and 

will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of 

death or serious bodily injury. With a small payload and maximum flight time of only 25-30 

minutes, they offer little or no risk to national security.

Low level oblique photos and video from several angles are far more effective than groundbased imagery for displaying the characteristics of large, structures and properties.

Additionally, we request that we be allowed to use our systems to benefit municipal Law

Enforcement Departments who might require assistance, including fire fighters, and other 

Federal Agencies.

Both UAS’s will be operated in the field with both a PIC and a Visual Observer in accordance 

with FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" and with the 

following Restrictions:

(a ) All operations must be within the restrictions of The California State Statutes governing UAS 

Operations;

(b) No flight will be made with a UAS Gross weight exceeding 55 pounds;

(c) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an 

airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;

(d) (All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation;

(e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 

(b), a minimum of 100 flight cycles and 25 hours of total time as a UA rotorcraft pilot and at least 

ten hours logged as a UA pilot with a similar UA type;

(f) The UAS’s will not be operated within 5 NM of an airport or heliport; (m) Operations will be 

conducted during VFR conditions with at least Class E weather minimums;

(n) The PIC will brief the VO and command staff about the operation and risk before the first 

flight at each new location;

(o) No flight may be made without a Pre-Flight Inspection by the PIC before each operation to 

ascertain that the UAS is in a condition safe for flight.

The PIC and VO will perform maintenance on the system and will complete a course of

maintenance instruction as part of their initial training.

We submit that the combination of the UA'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 (a) through (o) 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.

The name and contact information of the applicant is:
Rialto Police Department 

Richard Royce, Sergeant

128 N Willow Ave

Rialto, CA 92376

Tel: 909-820-2593

Email: RRoyce@rialtopd.com

We are 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 

clarification. Many thanks for your consideration.

Respectfully,

Richard Royce