Todd W arr Request for Exemption for Commercial UAS Operation Ma y 3, 2015

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## Todd Warr **Aerial Drone**  **Photography (ADP)**  **429 Autum n Chase Court**  **Purcellville, VA. 20132 1 (540) 338**  **- 8903**  **twarr3@yahoo.com** 

### U.S. Dep artment of Transportation Docket Management System 1200 New Jersey

Ave., SE Washington, D.C. 20590 **Subject: Exemption Request to Section 333 of the FAA Reform Act**  **and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3)(c)(d)(e)(f)(g)(h),**  **61.113 (a) & (b), 91.103, 91.121, 91.203, 91.151** Dear Sir or Madam : Pursuant to Secti on 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, Todd W arr, a licensed Private Pilot, hereby appl ies fo r an exem ption from the Code of Federal Regulations (C.F.R) , Federal Aviation Regulations (FARs) identified, to allow com mercial operation of lightwei ght Unm anned Aircraft Systems ( UAS) for aerial im aging and video. This exem ption is made based on inform ation outlined in this petition, to allow commercial operation of a YUNEEC Q500 UAS , so long as operations are conducted within and under the conditions outlined herein or as m ay be established by the Federal Aviation Adm inistration (FAA) as required by 333. **1 . Types of Operations**  T he requested exem ption would perm it the operation of sm all, unm anned m ultirotor aircraft under controlled conditions to provide the following services to the community;

a. Real Estate sales advertising b . Aerial Survey c. Aerial Photo/video d

. Prom otional advertising ma terial e. Inspections This exem ption would perm it operation of a n ultra - light weight, unm anned (piloted by rem ote control) in predeterm ined areas away from the general public, airports, heliports, and vehicular traffic. Operations would be conducted within federal guidelines, by a FAA Licensed Private Pilot with the assistance of a n Observer. Operations would be conducted after carefully reviewing, inspecting, and exam ining the area of aerial operation to e nsure the safety of persons and property.Todd W arr Request for Exemption for Commercial UAS Operation Ma y 3, 2015

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### 2 **. REQUESTED RELIEF**  I am requesting a grant of exemption of the following sections of Title 14 of the Code of Federal Regulations:

 **14 CFR 21;**  **14 CFR 91, et seq;**  **14 CFR 45.23 (b);**  **14 CFR 61.113 (a) & (b);**  **14 CFR 407 (a)(1);**  **14 CFR 409 (a)(2);**  **14 CFR 417 (a) & (b).** I am also requesting an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations for the following:

 **14 CFR 45.23 (b);**  **14 CFR Part 21;**  **14 CFR 61.113 (a) & (b);**  **91.7 (a);**  **91.9 (b) (2);**  **91.103 (b);**  **91.119;**  **91.121;**  **91.151 (a);**  **91.203 (a) & (b);**  **91.405 (a);**  **91.407 (a) (1);**  **91409 (a) (2);**  **91.417 (a) & (b). 14 C.F.R. Part 21, Subpart H: A** **irworthiness Certificates 91.7 (a)**  14 CFR § 91.203 Given the size, weight, speed, and lim ited operating area associated with the UAS aircraft to be utilized, I am asking exem ption from 14 CFR P art 21,Subpart H(Airworthiness Certificates) and §91.203 (a) and (b) (Certifications required), subject to certain conditions and lim itations, is warranted and m eets the requirem ents for an equivalent level of safety under14 CFR P art 11 and Section 333 of the Reform Act. The Federal Aviation Act U.S.C. 44701 (f) and 333 of the Reform Act both authorize the FAA to Exem pt aircraft from the requirem ent for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proxim ity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria dem onstrated that the UAS operated without an airworthiness certificate, in the restricte d environm ent and under conditions proposed , will be at least as safe, or safer, than aTodd W arr Request for Exemption for Commercial UAS Operation Ma y 3, 2015

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Page **3** of **6** conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed

. I request an exem ption from 14 CFR 91.7 (a) Civil Aircraft Airworthiness. **14 C.F.R. 45. 23**  **( b**  **): Marking of the A** **ircraft** Furtherm ore I request an exem ption from §45.23 Marking of the aircraft because m y UAS will not have a cabin, cockpit or pilot station on which to m ark certain words or phrases. Additionally two - inch lettering is difficult to place on such a small aircraft with dim ensions sm aller than the m inim al lettering requirem ent. Even though the UAS will have no airworthiness certificate, an exem ption m ay be needed. The word “Experim ental” could be placed on the UAS to com ply with 45.29 (f) in a size suitable for t he available space. The UAS is equipted with LED lights to aid in visibility. **14 CFR 61.113 (a) & (b): Private pilot privileges an d limitations: Pilot in command**  Under §61.113 (a) and(b) private pilots are lim ited to non - commercial operations, however I can achieve an equivalent level of safety as achieved by current regulations because m y UAS does not carry any pilots or passengers. I have a Private Pilots Licens e and will ensure all operations are conducted by a person with at a m inimum a Private Pilots Certificate. **14 CFR 91.9 (b) (2) :**  **Civil A ircraft Flight Manual in the A** **ir craft**  An exem ption to the part will be needed since there is nowhere to place a copy of a flight manual on board the UAS. **14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action** This requires each PIC to take certain actions before flight to insure safety of flight. There is no approved flight m anual, however the PIC will take actions prior to flight by reviewing the weather, flight battery requirem ents, and e nsuring there is a safe location to land and depart so as not to cause undue hazard to people or property on the ground. The manufactures manual w ill be used prior to flight to e nsure safety. **14 CFR 91.119: Minimum Safe A** **ltitudes** Due to the lim itation that operations be conducted at or below 400 feet AGL, an exem ption will be necessary to m eet 91.119. The typical UAS flight will be operated as follows: 1 ) Operate the UAS for 10 - 15 m inutes per flight, land m y UAS according to the manufacturer’s recommended m inim um level of battery power. 2 ) Operate m y UAS only within visual line of sight (VLOS). 3) Always obtain all necessary perm issions prior to operation. 4 ) P rocedures in place to abort flights in the event of safety breaches or potential danger.Todd W arr Request for Exemption for Commercial UAS Operation Ma y 3, 2015

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Page **4** of **6 14 CFR 91.121: A** **ltimeter Setting** The UAS is not equipped with an altim eter setting device. GPS will be used on board the UAS to determine altitude by reference to the ground (AGL). **14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions** An exem ption from 91.151 will be necessary as the norm al flight tim e will only be 10 - 15 m inutes. The UAS is fueled by battery power and a long duration flight is not po ssible. Also since all flights will be conducted Line of Sight (LOS), this requirement is not applicable. **14 CFR 91.405 (**  **a); 407 (a) (1); 409 (a) (2); 417 (a) & (b): Maintenance Inspections**  These regulations require the owner/operator to have the airc raft inspected as prescribed in subpart E of this part. An equivalent level of safety will be m aintained because of the small size and lim itations of this UAS. Maintenance will be accom plished by the operator pursuant to the owners m anual. The operator will ensure that the UAS is in proper working order prior to each flight, perform necessary m aintenance, and keep a log of maintenance. The operator is the person m ost familiar with the UASs operation and is best suited to m aintain in an airworthy condit ion to provide equivalent level of safety. **3 .**  **Commercial and Public Benefits**  G ranting this exem ption will by provide a safe (by way of a unm anned system) and efficient means to meet technical problem s solvable by elevated data collection instrum ents. Our typical custom er base is sm all to m edium size business and individuals who would be unable to acquire this service by m anned aircraft due to it being cost prohibited. By m oving these functions to UAS based ai rcraft not only can m ore people benefit from this service but it will reduce aircraft noise, pollu tion, reduce airport congestion. In addition, it will reduce the am ount of people and property exposed to the hazards of a ma nned aircraft flying at low alt itude with the potential for catastrophic results. There are no com bustibles on - board the UAS, thus eliminating the risk of explosion and fire due to a crash. The operation of t his UAS will m inim ize ecological dam age and prom ote econom ic growth by provid ing inform ation to companies in the area that would otherwise be unavailable. Additionally , this system would eliminate a distraction to air traffic control lers who mu st monitor an aircraft that usually wants' to take pictures in the "wrong place at the w rong tim e" thus reducing workload on ATC. The use of UAS, would allow these services to be provided and thus benefit bot h the community and aviation by: 1. Providing a lower cost to the individual needing these services. 2. Zero emissions from the UAS. 3. Reduced noise over an aircraft. 4. Reduced hazard to people or property on the ground.Todd W arr Request for Exemption for Commercial UAS Operation Ma y 3, 2015

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Page **5** of **6** The use of a UAV will provide a level of safety at least equal to existing rules and will only be operated in a safe environm ent that is strictly controlled. Operations will only be conducted after a careful review of the area and weather conditions. Safety is the num ber one priority. **4 .**  **SUMMARY** Granting this exem ption is a " win win " situation for individual s in need of this service. The community benefits from reduced pollution and noise. The econom y benefits by creating jobs for sm all businesses. The consumer benefits from reducing the cost of this service. The FAA benefits by regulating the use of UASs so that safety and accountability can be ma intained and monitored. Approval of exem ptions allowing comm ercial operations of UASs in the media will enhance safety by reducing risk associated with conventional aircraft operations. The operation of UASs weighting less than 55lbs by a certified pi lot will enhance safety to the community increase awareness of properly flow n UASs, elim inate the risk of collision with aircraft operating in the airspace and around airports and provide jobs.

Todd W arr Aerial Drone PhotographyTodd W arr Request for Exemption for Commercial UAS Operation Ma y 3, 2015

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**APPENDIX A: AIRCRAFT SPECIFICATIONS**  **1. YUNEEC**  **Q500: 4 Rotor, Electric Driven, Quad -** **Copter :** 

o **Flight Time Up to 25 Minutes**  o **Dimension 16.5x16.5x9.5in**  o **Diagonal Length Without Rotor Blades 22.2in**  o **Propeller/Main Rotor Diameter 13.0in**  o **Weight Without Battery and Payload**  **40.0oz** o **Battery 5400mAh 3S 11.1V LiPo (included)**  o **Transmitter 10 Channel 2.4GHz with 5.8 GHz video downlink**  o **Flight Modes Smart Mode and Manual Mode**  o **Maximum Speed**  **12MPH** o **Maximum Flying Height Default 400ft Above Ground**  **Level** o **Maximum Rotation Rate 65**  **0 per second**  o **Maximum Roll Angle 35**  **0** o **Radio Control Frequency Band 2.4 GHz**  o **Operating Temperature Range -**  **5 0**  **C to 80 0**  **C 2.**  **GROUND STATION SPECIFICATIONS:**

o **Operating System Andriod**  o **Number of Channels 10**  o **Control Transmission Distance/Range (Optimum Conditions)**  **FCC Compliance Up to 800m (2624 ft) CE Compliance: Up to 400m (1312.34 ft) Warning You Must Follow Local Laws and Maintain Visual Line of Sight of Aircraft at All Times** 

o **Robust Radio Control Modulation Yuneec Protocol**  o **Video link Frequency Band 5.8 GHz**  o **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 Laws and Maintain Visual Line of Sight of Ai** **rcraft at All Times** o **Flight Systems Telemetry Data On Screen Display (OSD) Yes**  o **LED Backlit LCD Screen Capacitive Multi** **- Touch 4.5"**  o **Tactile (Vibrating) and Audible Feedback Yes**  o **Built -** **In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh**