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 descri bed Unmanned Aerial System called

in this application Yuneec Typhoon and Instanteye MK2 Gen3 which includes an Unmanned Ariel System (UA S ) and ground station

- based equipment and crew:

THE UNMANNED SYSTEM (UA S ):

Yuneec Typhoon and Instanteye MK2 Gen3 : The inherent safety feature s, 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 muc h safer UA S for the purposes of this
petition. These are radio controlled UA S ’s that have the ca pacity for software upgrades. They

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

of these UA S ’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 , a llowing 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 UA S ’s allows the operator or PIC to set maximum altitude AGL for each fligh t, allowing
customization of flights to no higher than 150 feet can be programmed into the UA S 's software

pre

- flight to insure compliance with FAA standards, a dding to the safety capabilities of these

UA S ’s. These UA S ’s are programmed to remain in posit ion when controls are released,

m aintaining altitude and GPS location.

Both UA S ’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 oper ator or

PIC can monitor GPS lock status while UA S 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 UA S ’s are also equipped
with a safe dynamic return to home function and automat ic 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 UA S ’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 p hotos and video from several angles are far more effective tha n ground

based imagery for displaying the characteristics of large, structures and properties.

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

E nforcement Departments who might require assistance, including fire fighters , and other
Federal Agencies.

Both UA S ’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 Requi rements for UA S " and with the
following Restrictions:

(a ) All operati ons must be within the restrict ions of The California State Statutes governing UA S
Operations;

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

(c) All operatio ns 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 b e 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 UA S ’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 UA S is in a condition safe for flight.

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

m aintenance 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 un der 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 miss ion.

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 le vel of safety. Please contact me at any time if you require additional information or
clarification. Many thanks for your consideration.

Respectfully

,

Richard Royce