Page 1 of 4 March 14, 2016

US Department of Transportation Docket Operations 1200 New Jersey Ave. SE Washington, DC 20590

RE: Request for Exemption of Section 333 of the FAA Modernizati on and Reform Act 2012.

Name and Address of Petitioner:
Neil A. Monkman
908 SW 4 th Ave Cape Coral FL 33991

Working for: Wright Construction Group, Inc. 5811 Youngquist Rd. Fort Myers FL 33912 Project Manager/Quality Control Manager/Radiation Safety Office r

Authorized Associate:
Brian McWilliams IT Manager – Wright Construction Group 5811 Youngquist Rd. Fort Myers FL 33912

To Whom It May Concern:

Pursuant to Section 333 of FAA Mo dernization and Reform Act of 2012 (hereinafter “the reform act”) and 14 FCR Part 11, Neil A. Monkman, The Petitioner, hereby req uests an exemption from the following Federal Aviation Regulations in order to legally operate an Unm anned Aircraft System (UAS) in the National Airspace System and, with written consent from the FAA and on occasion to fly within specific national airport airspace as noted herein.

Regulations from which the exemption is requested:
14 CFR 21 H 14 CFR 45.23(b) 14 CFR 91.9 (b)(2)
14 CFR 91.119Page 2 of 4 The petitioner wishes to be gran ted the exemption for use of th e UAS of commercial operations listed
below.

Applications and Operations:

 Overhead Photography of Bu ilding Construction Sites

 Overhead Photography of Roadwa y/Utility Construction Sites

 Overhead Video of Building, Road way or Utility Construction Sit es

The petitioner believes the use of the UAS for the above applic ations provides the following benefits.

 Cost Savings – Typical overhead photos of this type are taken b y manned aircraft at a significantly higher cost. This h igher cost is passed on to eit her the property owner of private land projects or to the tax pay er on public/federally funded ro adway projects. There is also a cost savings to any governing agency requiring far less time an d effort with monitoring and/or approving the use of a UAS.

 Safety – In the rare event of a failure during flight due to an y unforeseen circumstances, the resultant damage to person or pr operty would be minimal if non‐ existent due to the areas being flown are typically non‐populated or less populated. Additional ly, since this specific type of UAS does not use fossil or combustible fuels, the risk is much lowe r. Lastly, due to the small mass of the UAS any impact damage would be minimal.

 Environmental – The UAS does no emit any toxic substances as a result of operation. It uses rechargeable batteries which are more environmentally friendly.

UAS Characteristics/Features/Specifications:

The UAS Specifications are as follows: Model: Yuneec Typhoon Q500 4K
Dimensions: 210mm x 420mm Diagonal Motor to Motor Distance: 510mm Propeller Diameter: 330mm Weight Without Battery: 1130g Weight with Camera & Battery: 1700g Battery: 5400mAh 3S 11.1V LiPo
Transmitter: 10 Channel 2.4Ghz with 5.8Ghz video downlink Maximum Flying Altitude: De fault 400’ Above Sea Level Maximum Rotation Angle: 35 degrees Maximum Climb Rate: 2m/s Maximum Descent Rate: 3m/s

Controls: Manual: The UAS is controlled by a remoted ST10+ controller tha t controls altitude, forward, side and
reverse motion. Maximum fo rward speed is 22 mph.
Automatic: In the event of loss of sight or video, the ST10+ controller ha s a single “home” button that will immediately return the UAS to the controller, maintaining curre nt altitude and then land within 20’ ofPage 3 of 4 the controller. Then automatica lly shuts down. Additionally, th e UAS has a series of “low battery alerts”. The first alert limits height t o 190’ above sea level, the crit ical alert will automatically land the UAS.

Exemption Requests & Reasons

14 CFR 21 H: Airworthiness Certificates The petitioner has been unable to obtain these types of certifi cates that are typically required for manned aircraft. It is also the petitioners understanding that similar UAS’s do not require these as granted in Exemption N os. 11623, 11650, 11664 and 11734.

14 CFR 45.23 (b) Marki ng of the Aircraft These regulations provide that ea ch aircraft must display “N” a nd the aircrafts regi stration number in letters at least 3” high. Additio nally, the aircraft must displ ay the word “EXPERIMENTAL” in letters at least 2” high near the entrance to the cabin, cockpit or pilot station. None of the l ocations exist on the
UAS and due to its size 2” or 3” letters will not fit.

14 CFR 91.9 (b) (2) Civil Aircra ft Flight Manual in the Aircraf t Because this is an unmanned airc raft, a flight manual in the ai rcraft would serve no purpose as the pilot is on the ground. Also, there is nowhere to put such a manual o n the UAS. The operator will always have
the most current user manual rea dily available for reference.

14 CFR 91.119 Minimum Safe Altitudes The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, v ehicle or structure.  While th e maximum forward speed is 22 mph, the operations for what this UAS w ill be used for will result in a maximum forward speed no more than 5‐10 MPH or slower. Flying any faster than that would not produce th e desire effect of construction progress photos or videos. Also, because the UAS will be used for both b uilding and roadway construction it will frequently be within 500 feet of any of the above. An exemption is requested due to the fact the use of the UAS will typically be in are as not open to the public and t he petitioner will always take means to ensure the safety of anyone in t he site including providing adv anced notice of any flight.

Additional Reasons: The current software/firmware o f the controller will NOT allow the UAS to start or fly within any no‐fly
zone. This feature cannot be ove rridden. Many construction proj ects are performed within the no fly zones of several local airports in 3 counties. Without the exem ption there is a hardship created financially by having to use compa nies that fly manned aircraft

.

The manufacturer has a version of firmware that will allow the UAS to fly within no fly zones, but they require the exemption to be grant ed before they will release th e firmware to any consumer.Page 4 of 4 Additional Safety Precautions and Measures to be Taken:

1. The petitioner will always ensure that a copy of the registrati on for the drone is readily
available.
2. The petitioner, if requested or required, will affix the regist ration number to the UAS
3. The petitioner has undergone several hours of training and is w ell versed in the controls and requirements.
4. Routine maintenance and inspecti ons will be performed in accord ance with the manufacturer recommendations or by the manufact urer to meet the general inte nt of 43.7 of this chapter

5. The petitioner will always perform a “pre‐flight” safety check
6. The petitioner will continuously monitor the altitude and surro unding hazards.

7. While the firmware will allow fli ght within a no fly zone, the petitioner will always have a current map of all current no fly zones readily available.
8. In NO CASE will flight occur withi n a no fly zone without first contact the appropriate FFA, Airport Operations Staff or any other required governing agency

. 9. When construction projects are within a no fly zone, the petiti oner WILL establish a mutually agreed upon operating procedure with airport operations and FAA staff. If requested, a site specific safety plan will be developed.

In summary, the Petitioner (Neil A. Monkman) herby requests an exemption as noted herein as well as any other requirement not specif ically listed but incidental to the exemptions herein and necessary to perform the scope of “Aerial Pho tography and/or Video of Roadwa y or Building Construction Projects” and/or to legally operate an Unmanned Aircraft System in the Na tional Airspace System and, on occasion and with proper notice and approval, within designated no fly zones.

Most Respectfully,

Neil A. Monkman
908 SW 4 th Ave. Cape Coral FL 33991
239‐462‐7371 cell
239‐481‐5000 office neilm@planetmonkman.com