January 24, 2016

Federal Aviation Administration (FAA) Attn : Docket Operations, M

-30 U. S. Department of Transportation (DOT) 1200 New J ersey Avenue, SE. Room W12
- 140 West Building Ground Floor Washington, DC 20590

-0001 **PETITION FOR EXEMPTION UNDER SECTION 333**  **FOR LYMAN HOWARD** 

### 1. Petitioner Name and Contact Information Mr. Lyman Howard 317 Ross Drive Mill Valley CA 94941 415
- 381
- 3964 Lyman415@gmail.com 2. The Specific Section or Sections of 14 CFR from Wh ich I Seek an Exemption 

### 14 CFR Part 21 Subpart H 14 CFR 91.105 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151 14 CFR 203(a) & (b) 14 CFR 91.405 14 CFR 91.407 14 CFR 91.409 14 CFR 91.417 3. The Extent of Relief I Seek, And the Reason I Seek the Relief **PETITION FOR RELIEF OF REQUIREMENT** **S OF TITLE 14 OF THE CODE**  **OF FEDERAL REGULATIONS, SPECIFICALLY AS AUTHORIZED UNDER THE F.A.A. MODER**  **NIZATION AND REFORM ACT OF 2012 SECTION 333;**  **SPECIAL RULES FOR CE RTAIN UNMANNED AIRCRAFT SYSTEMS** I, Lyman Howard , seek exemption from those elements of Title 14 of t he Code of Federal Regulations

listed above in order to operate a Yuneec Q500 4k Unmanned Aircraft System ( UAS ) . This exemption will allow me to operate an unmanned aerial vehicle c ommercially for the purposes of collecting aerial video and st ill photography to support Tourism and Real Estate . I intend to contract with local area commercial and residential real estate professionals, providing them compelling imagery of properties for sale and local scenery for promotional purposes. My UAS is a Yuneec Q500 4k electric quad copter capable of capturing high quality photographs and video from an integral onboard CGO3 camera. It has a maximum takeoff weight of 3.75 lbs and maximum horizontal speed of 22 mph. The defa ult maximum altitude setting is 400ft AGL. Maximum flight time is 25 minutes. The radio control transmitter is factory set to operate in the 2.4 GHz band, and video is transmitted via 5.8 GHz downlink. A “Home” mode exists which can be activated by the PI C, automatically engaged when radio contact is lost or when battery reaches a critical minimum, and which returns the aircraft to a predetermined landing spot autonomously. Due to t he small size of the aircraft and its short range, plus the fact that it carries no passengers or pilot onboard, I believe that my proposed operatio ns merit exemption from certain requirements for the National Airspace System which I cannot fully comply with , specifically: 

### 14 CFR Part 21 Subpart H

- Certification procedures for products and parts, Airworthiness Certificates . I request permission to determine airworthiness based on manufacturer’s guidance and my own preflight inspections and maintenance. 

### 14 CFR 91.105

– Flight crewmembers at stations. Relief is requested due to lack of crew stations aboard this unmanned aircraft . My aircraft will require line of sight operation with hands on the radio transmitter by the Pilot in Command (PIC) and accompanied by th e Visual Line of Sight Observer (VLOS) throughout the duration of flight. 

### 14 CFR 91.109
– Flight instruction. Relief is requested to allow for training of PIC without dual redundant controls inside the aircraft . The radio transmitter can be safely passed from instructor to student and back during dedicated training flights. 

### 14 CFR 91.119
– Minimum Safe Altitudes. Relief is requested to the extent that operations will always be conducted below 500 feet al titude and the required minimum altitudes will therefore not be met except to maintain absolute 500 feet distance from non - participating persons, vehicles, vessels, or property at all times. 

### 14 CFR 91.121
- Altimeter Settings. Relief is requested due to the nature of altimeter readings of this aircraft. Instead of setting a barometric altimeter to locally reported sett ings, this aircraft uses GPS plus an internal barometric sensor to provide altitude readouts. 

### 14 CFR 91.151
– Fuel Requirements for flights in VFR conditions. Maximum flight time on a battery is 25 minutes. Request relief to the extent that a 5 minute battery reserve at landing is sufficient minimum fuel aboard.

### 14 CFR 203(a) & (b)
– Civil aircraft; certifications required. I request permission to fly

without evidence of airworthiness and registration displayed in the cockpit or cabin of the aircraft, which is not so equipped. A copy of aircraft registration and any Section 333 exemption letter will be in the possession of the PIC during operations and avail able to law enforcement
. 

### 14 CFR 91.405, 14 CFR 91.407, 14 CFR 91.409, 14 CFR 91.417
– These se ctions re late an airworthiness certificate, and none exists for a small UAS such as my Yuneec Q500 4k. 4. The Reasons Wh y Granting My Request Would Be in the Public Interest My request is in the public interest as my service delivers a far more cost effective means to the local business community in providing quality marketing and informational aerial video . Buyers and sellers will be able to more accurately assess the value of a property. This is an economic benefit to the community. Ad ditionally, by using a small electric UAS in place of a manned aircraft in gathering aerial photographs and video, noise and air pollution is reduced and safety enh anced. Traditional manned aircraft weigh thousands of pounds and carry quantities of flammab le liquid fuels. A small UAS would therefore be less of a safety hazard to those on the ground following a mishap. Finally, each additional approved commercial UAS operator available means that aerial work is less likely to be performed by an unauthorized hobbyist
. Unauthorized hobbyists are less likely to be operating with safety of other aircraft or people on the surface in mind. 5. The Reasons Wh y Granting the Exemption Woul d Not Adversely Affect Safety, o r H ow the Exemption Would Provide a Level of Safety at Least Equal to That Provided by the Rule from W hich I Seek The Exemption Safety will not be sacrificed if my request for exemption is granted. Operations will be conducted according to procedure and checklists. A preflight inspection will ensure that the aircraft has all required parts and is functioning according to manufacturer’s instruction. The PIC will clear the local vicinity of n on - participating people and ensure there are no collision hazards. The aircraft itself has flight stabilization software that allows it to hold its orientation level in space and position, plus a n autonomous return
-to
- base mode. It notifies the PIC of low aircraft battery voltage with visual, audio, and “shaker” notifications. The aircraft will be operated by a cert ificated airman m eeting applicable flight review requirements
. There wi ll be a dedicated VLOS present at all times
. Flights will originate from legal and approved property and be clear of towered airports by 5 miles and non

-towered by 3 miles. The ma x altitude will be 400 feet AGL, flights conducted in daylight only under line of sight an d remaining clear of clouds by 5 00 feet below and 1,000 feet laterally with a minimum visibility of three mile s . 6. A Summary the FAA can Publish in the F EDERAL R EGISTER , Stating: (a ) The rule from which I seek the exemption;“As authorized under t he F.A.A . Modernization And Reform Act of 2012 , section 333;

S pecial Rules For Certain Unmanned Aircraft Systems, Lyman Howard hereby seeks exemption from th e following sections of 14 CFR for th e purposes of operating a UAS for the collection of aerial video and photographs: 

### 14 CFR Part 21 Subpart H 14 CFR 91.105 14 CFR 91.109 14 CFR 91.119 14 CFR 91.121 14 CFR 91.151 14 CFR 203(a) & (b) 14 CFR 91.405 14 CFR 91.407 14 CFR 91.409 14 CFR 91.417” (2) A brief description of the nature of the exemption I seek;

“ Lyman Howard submits that granting him an exemption will not adversely affect safety and is in the public interest. His commercial operations will be in service to the real estate and tourism industries and conducted in ac cordance with safety procedures. ” Respectfully Submitt ed,

Lyman Howard