October 23, 2015 U. S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 ·,. '{'>

Petition ofC & H Drone Services LLCfor Exemption Pursuant to Section 333 ofthe FAAReform Act

Petitioner's Name and Address: C & H Drone Services LLC Owner: Marion Stewart CantyJ r Owner: George Hooker Address: P.O. Box 630953 Nacogdoches, TX 75963 Email: stewartcanty@yahoo.com Mobile Phone: 936-615-8247

To whom it may concern: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.P.R. Part 11, C & H Drone Services LLC operator ofSmall Unmanned Aircraft (UAS) equipped to conduct aerial photography and videography, hereby applies for an exemption from the listed Federal Aviation Regulations ("PARs") to allow commercial operation ofits UAS, so long as such operations are conducted within and underthe conditions outlinedherein or as maybe established bythe FAA as required by Section 333.1

As described more fully below, the requested exemption would permit the operation of small, unmanned, and relatively inexpensive UAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, ifgranted, would allow C & H Drone Services LLC to conduct commercial operations of UASmeeting or exceeding all ofthe operational and safetyrequirements Congress has set forth in Section 333. C & H Drone Services LLC is a graphic design and photography company owned and operatedby Marion StewartCanty Jr and George Hooker. Marion Stewart CantyJr is a Commercial instrumentrated Pilot and has serveral years ofexperience flying RC airplanes. Thepurpose ofC & H Drone Services LLC is to provide aerial photography and video services for marketing purposes inthe areas of EastTexas.

C & H Drone Services LLC plans to use the capabilities ofUAS to offer a multitude of services, including:

• Aerial surveying ofproperties ownedby clients
• Architectural and landscapephotography
• RealEstate and Commercial Real EstatePhotography andpresentation
• Aerial filmmaking andphotography
StatutoryAuthority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expeditedFAA authorization ofsafe civil UnmannedAircraft Systems (UAS) operations in the National Airspace System ("NAS"). Section 333(a) states that theFAA "shall determine ifcertainunmanned aircraft systems may operate safely inthe national airspace systembefore completion ofthe (comprehensive) plan andrulemaking required by section 332(b)(l) ofthis Act orthe guidance requiredby section 334 ofthis Act." In Section 332(b)(l), Congress made it clearthat Section 333 provides a mechanismfor "expeditedoperation authorization" if several factors are met. Petitionermeets all requirements to permitFAA approval of commercial UAS operations.

Thename and address ofthe applicant are:Name: C & H Drone Services LLC Owner: Marion Stewart CantyJr Owner: George Hooker Address: P.O. Box 630953 Phone: 936-615-8247 Email: stewartcanty@yahoo.com
Regulations from which the exemption is requested: 14 C.P.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b)(2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401- 91.417)

UAS are oftentimes seen as superiorto helicopters due to the lesser cost ofequipment, the reduction ofpersonnel needed to operate equipment, reduced noise levels and zero emissions into the environment. In addition to providing cost savings andhaving little to
no impact onthe environment, UAS provide enhanced safety. These factors are beneficial for, and in the best interest of, the public. Accordingly, the applicant respectfully requests that theFAA granttherequested exemption without delay.

Marion Stewart CantyJr and George Hooker are requesting an exemptionto enable C & H Drone Services LLC to operate a Yuneec Typhoon Q500, UAS thathas beenupgradedto latest version firmware, equipped with a 3 axis stabilization gimbal, which uses a High-Defvideo camera that can capture up to 4K (4096x2160p) video and 12Mpixel photos. This UAS has a built-in capability to limit 1) theheight it flies above the ground and 2) the radius ofthe distance it flies from the operator. The Yuneec Typhoon Q500 also has failsafe functions ofthe autopilot system, which means, when the communicationbetween the Main Controller and the transmitter is disconnected, the outputs ofall command sticks from controller will go to the center position. Ifthe GPS signal is good enough, the system will automatically triggerReturn to Home and will land safely.

Pleaserefer to Attachments! and 2 for the Yuneec Typhoon Q500, for the performance limitations and flight operations. AircraftWeight is 1700 Grams or 3.98 pounds with battery, which is the total gross weight..

A pre-flight inspection will beperformed bythe PIC in accordance with the factory instruction manual, as well as redundant checks to include the Internal Measurement Unit (IMU) to make sure that the compass, gyro and acceleration values are within specs, positive GPS locks are secure, batteryhealth in each individual LiPo cells are balanced, and radio signals are locked in.

The UAS will be maintained in accordance with the manufacturer's instruction manual and only manufacturer's authorized replacementparts will beused.

FCC Information TheYuneec Typhoon Q500 transmitter used for controlling the UAS complies with part 15 ofthe FCC rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept anyinterference received, including interference that may cause undesired operation. The Yuneec Typhoon Q500 radio transmitter used for controlling the UAS is wireless technology, which has beentested and found to be compliant with the applicable regulations governing a radio transmitter in the 2.400 GHz- 2.483 GHz range.

Antenna Separation Distance When operating the Yuneec Typhoon Q500 transmitter, the PIC will maintain a separation distance ofat least 5 embetweenhis body (excluding fingers, hands, wrists, ankles and feet) and the antenna to meet RFexposure safetyrequirements as determined by FCC regulations.

Pilot in Command and Observer Qualifications and Duties ThePIC will maintain at least aPrivate Pilot Certificate and a current Class III medical, plus at least 6 hours flying time and 5 takeoffs and landings within 30 days inthe type of UAS utilized in operations.

ThePIC is responsible for the safe and efficient operation ofthe aircraft. Specific duties include all preflight preparation and inspection, in flight operation, postflight requirements, and all procedures including but not limitedto:
• Safe in flight operations
• Risk evaluation
• Current weather conditions for safe flight

The Observer musthave the visual acuity to observe the UAS and be able to communicate clearly with the PIC. The Observers duties are:
• Warning the PIC ofany impending obstacles in the flight path ofthe UAS.
• Warning the PIC ofany deviations inthe planned flight path ofthe UAS.
• Warning the PIC should any unauthorized personnel appear in the area ofthe planned flight.
• The Observer will have the authority to order the PIC to terminate the flight should he feel the flight can notbe conducted safely.General Operating Standards
• C & H Drone Services LLC will only operate its UAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated
areas. Such operations will insure that the UAS will "not create a hazard to users ofthe national airspace system orthe public."
• Before an operation ofthe UAS within 5NM ofan airport with a control tower, the control tower will be called to gainpermissionto operate the UAS. The PIC will give the position, altitude and the times the UAS will be operated. TheUAS will notbe operated at an altitude ofover 200 feet AGL. Weather minimums will be 3 miles visibility and a 1000-foot ceiling.

· Before an operation ofa UAS within 5NM ofa non-tower controlled, airport operators will be notified and the PIC will give the right ofway to avoid flying intheproximity of full-scale aircraft. Atno time will the UAS be operated within the final approach course and the takeoffcourse ofany runway. The UAS will notbe operated at an altitude ofover 200 feet AGL. Weather minimums will be 3 miles visibility and a 1000-foot ceiling.
• Maximum flight time for each operational flight will be 15 minutes.
• Flights will beterminated at 30% battery powerreserve should that occurprior to the 15 minute limit.
• The UAS will beprogrammed so that they will notbe operated at an altitude ofno
more than 200 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned.
• Minimum crew for each operation will consist ofthe UAS Pilot, and Visual Observer.
• The UAS operatedbythe petitioner weigh less than 55 pounds, including thepayloads (i.e. camera, lens, and gimbals).
• The UAS will operate at speeds ofno more than 25 knots, can hover, and can simultaneously move vertically and horizontally.
• Given the small size ofthe UAS and the restricted sterile environment within which they will operate, my UAS operations adhere to the Reform Act's safety requirements.

\TheUAS, poweredbybatteries, are smaller, lighter and more maneuverable than larger aircraft running on combustible fuel. The UAS operate at lower altitudes with no persons
onboard and will thereby reduce current risk levels, enhance safety and diminish the likelihood ofdeath or serious bodily injury. With a small payload and maximum flight time ofonly 15 minutes, this offers little or no risk to national security. Low level oblique photos and video from several angles are far more effective than ground based imagery for displaying the characteristics oflarge, complex properties with several buildings and large trees. Thebenefits ofreduced costs and improved quality of presentation from the UAS over manned aircraft will be valuable to and benefit many buyers and sellers ofreal property including commercialbuildings, all while remaining subjectto all limitations citedbelow:
a No flight will be made with a Gross weight exceeding 55 pounds; b All operations must occur inFAA Class G airspace at no more than 200 ft AGL, at an airspeed ofno more than 25 knots and no further than 1600 ft, or0.263 NMfrom the PIC;
c All operations must utilize a visual observer (VO). The VO and PIC mustbe able to communicateby voice at all times during a flight operation; d Operations will berestricted to flights overprivate property with the permission ofthe property owner;
e All required permits will be obtained from state and local government prior to operation; f C & H Drone Services LLC will notbe operated over densely populated areas; g C & H Drone Services LLC will notbe operating over any open-air assembly of people; h C & H Drone Services LLC will not be operating overheavily trafficked roads; (i) C & H Drone Services LLC will not be operating at night.



### EXEMPTIONREQUESTS AND EQUIVALENT LEVEL OFSAFETY C & H Drone Services LLC requests an exemption from the following regulations as well
as any additional regulations that may technically apply to the operation ofthe UAS Systems:14 CFRPart 21, Airworthiness Certificates This part establishes the procedures for the issuance ofan airworthiness certificate. While the FAA continues to work to develope airworthiness standards for Unmanned Aerial Systems, Irequest an experimental certificatebe issued for the Yuneec Typhoon Q500 under either orboth ofthe following provisions: 21.191 Experimental certificates. Experimental certificates are issued for the following purposes: b 

### Research anddevelopment. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, ornew
uses for aircraft.
c 

### Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliancefor issuance oftype and supplemental type certificates, flights to Substantiate major design changes, and flights to show compliance with the function and reliability requirements ofthe regulations. Since the experimental certificate canbeused for commercial purposes such as market surveys, sales demonstrations, and customer crew training, I would expect that an experimental certificate would permit my commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with theUAS lightweight, being constructed primarily ofcarbonfiber and plastic, Ipropose that the VAS will be at least as safe, ifnot safer, than a conventionally certificated aircraft performing the same mission. Ifan experimental airworthiness certificate is not appropriate for this application, then Irequest an exemption of 14 CFRPart 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level ofsafety outlined inthe previous paragraph.

14 CFR45.23 Display ofmarks; general and 45.29 Size ofmarks. Theseregulations provide that each aircraft must display "N" and the aircraft's registrationnumber in letters at least 3 inches high. Additionally, the aircraft must displaythe word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAS do not have an entrance in which the word "EXPERIMENTAL" canbeplaced, and may nothave a registration number assigned to it bythe FAA. I propose to achieve an equivalent level ofsafetyby including the word "EXPERIMENTAL" in the placard onthe top ofthe aircrafts, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity ofthe aircraft while it is preparing for launch will be able to see the designation. Additionally, I feel that the permanentplacard discussed in the previous paragraph will provide the aircraft's registration information atthe ground station. Finally, I will display at the ground station
ahigh contrast flag orbannerthat contains the words "Unmanned Aircraft Ground Station" in letters 5 inches high or greater. Since the aircraft will operate within 0.263 NM ofthe ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point oforigin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. Theregulation provides that no person thatholds a Private Pilot certificate may act as pilot in Command ofan aircraft for compensation orhire. Subparagraph (b) allows a private pilot to act as pilot in command ofan aircraft in connection with any business or employment if: (1) The flight is only incidental to thatbusiness oremployment; and (2) The aircraft does not carry passengers orproperty for compensation orhire. Ourproposed operations require that the PIC must hold at least a Private Pilot Certificate with a Class III Medical issued by the FAA and since the aircraft cannot carry passengers orproperty, I feel I meet the intent of61.113 Subparagraph (b) even though the intent ofthis application is to conduct a business.

14 CFR 91.7 Prohibits the Operation ofan aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplatedbythe FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.This regulation provides that no person may operate an aircraft unless a current, approved flight manual is inthe aircraft. I assume that the intent ofthis requirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. I request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level ofsafety and meet the intent of91.9, I propose that a current, approved UAS Flight Manuals mustbe available to the crew at the ground station anytime the aircraft is in, orpreparing for flight, and beready for presentation for any governing official upon request.

14 CFR 91.109 FlightInstruction; Simulatedinstrumentflight and certain flight tests The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls. C & H Drone Services LLC will be operating with a single remote controller for the Yuneec Typhoon Q500.

91.119 Minimum safe altitudes: General. Theregulation states that over sparsely populated areas the aircraft cannotbe operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the typical mission ofthe UAS would be to acquire photographs orvideo ofbuildings or commercial structures, it would benecessary to operate closer than 500 feet to the items listed. Operations will onlybeflown overproperty where permissionhas been obtained and careful preplanned flight pathhas beenperformed. The aircraft will be operated at a low altitude allowing, ifa powerunit fails, an emergency landing without undue hazard to persons orproperty onthe surface. Therefore I maintain that due to the small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

CFR91.121 Altimeter settings.Theregulation requires that aircraft shall maintain cruising altitudes byreference to an altimeter setting available within 100 NM ofthe aircraft. The UAS will always fly below 200 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UAS on-board computer to the display screenheld by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. Theregulation provides that no person may begin a flight in an airplane under day-VFR conditions unless there is enough fuel to fly to the first point ofintended landing and to fly after that for at least 30 minutes. Ifeel the intention ofthis paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UAS is battery operated and the maximum duration offlight from a single battery charge is 18 minutes with a 20%
reserve. Sincethe aircraft will never fly more than 0.263 NM from the point ofintended landing, a full battery charge at launch will ensure that I meet the reserve energy requirement ofthis paragraph. Irequest an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy".

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. Theregulationprovides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate mustbe aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificatebe "displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew." At a maximum gross weight of3.98 pounds and, the UAS is too small to carry documentation, do not have an entrance, and are not capable ofcarrying passengers or crew. To obtain an equivalent level ofsafety and meet the intent of91.203, Ipropose that documents deemed appropriate for these aircraft bythe FAA will be with the crew at the ground control station and available for inspection upon request. In orderto identify the aircraft, I propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.14 CFR SubpartE (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation provides that the operator is primarilyresponsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraftbe "approved for return to serviceby a person authorized under 43.7" after maintenance and inspection. It is my intention that the PIC perform maintenance and inspection ofthe aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircrafts are in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours offlight. Maintenance performed bythe PIC is limited to, replacing a propeller, checking electrical connections and updating software and firmware for the onboard computer. The manufacturer ortheir designated repair facility will perform all other maintenance. The PIC will document work performed in accordance with 91.417. I feel that due to the size, construction, and simplicity ofthe aircraft, the PIC can ensure an equivalent level ofsafety.
Safety and Benefits ofthe UAS C & H Drone Services LLC will be using the UAS in a variety ofapplications that generally require expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer more efficient and safer benefits over the use offull-sized manned aircraft for aerial photography, film and still photography, real estate and commercial real estate marketing. C & H Drone Services will be able to provide services to clients that have not been availablebefore the technologybecame accessible. The benefits that come along with the permitteduse ofthe UAS are immense, and provide valuable image and video, useful for garnering interests in potential consumers, benefiting all parties involved.
Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin ofsafety for the pilots and crew. By granting C & H Drone Services LLC 's requested exemptions, theFAA will help drive development ofsafe and successful commercial UAS operations and will advance the publicknowledge base for such operations. C & H Drone Services LLC is committed to promoting the UAS research efforts ofpolicymakers including the FAA, NASA, DOD and DARPAby sharing data from its commercial UAS operations and serving as a resource for future UAS research operations. Thus, the FAAhas good cause to grantthis Petition.

Conclusion As pointed out in this application, the Yuneec Typhoon Q500, which I would use under authorization bythe US DOT-FAA, is a small, light-weight device operated within the line ofsight ofthe Pilot-in-Command (PIC), less than 200 feet above the ground and outside 5 miles from any airport, heliport, seaplanebase, spaceport, or other location with aviation activities, unless the air traffic control authorities (ATC) have beennotified and have authorized each flight within a radius ofthis distance. The YuneecTyphoon Q500 has beenproven capablefor controlled flight. This UAS is offered for general sale on the market around the world andhave often beenused as Model Aircraft inthe USA. I am certainthat the studies conducted until now bythe FAA, about Section 332, Public Law 112-95, 2014, have already provided you with the
assurances onthe airworthiness ofUAS such as mine.

Forthe foregoing reasons, the exemptions requestedherein should be granted and C & H Drone Services LLC shouldbepermitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate by the FAA.

The submission ofthis application and its contents is the best demonstration that indeed it is possible to pursue the authorization process so that some UAS maybeusedfor legitimate commercial activities and under reasonably safe conditions. Thank you for your time.
Formally SignedMarion Stewart Canty**JR,.....::::::::::~;::::sc~=** George Hooker

# QSOO TYPHOON 

# ,Aircraft Flight Time Up 

# to 25**Mi1n~ute~s** 

# Height2.40mm ('9

..45**ii~n)** 

# Width**42,·0m~m ~(16.54**  

# i1n)**Dlagon~~al** 

# Length

# Wi1tho:ut Rotor**Bilade~s** 

# S6Sm1m (22.2 iin)**P~rop.eller/Main** 

# Rotor**Dia~~meter** 

# 33·0mm (13.0 

# in)**we~igh~t** 

# Without :Ba:ttery**and~ Payil~o.ad:** **113~0g (4~0.0**  

# oz) 

# Battery 

# 54.QOmAh 35 11.1V 

# LiPo**{iinclud~e~d)** 

# Charger 35 11.,1V LiiPo 

# DC**IBa,la~ncing** 

# Smart 

# Charger with AC A.dapter 

# (Included) Transmitter 1·Q

...

# chan1nel .2.4GH:z**with~ 5~.8GHz**  

# video 

# downlin:k**(include~d)** 

# 3 

# F:light IModes Smart, 

# Angle 

# and Hom:e 

# Modes**Maximu~m** 

# Flying Height Default400**IF~eet** 

# Above 

# Ground 

# Level**(Ad~ustable** 

# v:ia 

# the· QSOO GUI) 

# Maximu:m Rotation,al Velocity 

# 65°/:S Maximu,m 

# Ba,nk Angle 35° 

# Maximu:m 

# Climb Rate in 

# Smart a:nd Angle mode 3m/s 

# Maximum D·escent Rate in Smart and Angle



# . 

# - .

# CG02-GB**Ca.m~era** 

# Gimbal 

# Syste·m**Fo~c:using Syste~m**  

# Aeriail**O~ptimiz.ed F:i1xe~d**  

# Focus**Vid~eo Re~solution**  

# FULL !H:.D 11 

# 080p·- Adjustable 

# 60, .50 or

# 48 FPS 

# P·h,oto Resolution 

# 12**Mega~p~ix.els** 

# Field ofView 155° 

# ST1 0 Personal Ground! Station Ope·ratingSyste.m Android!TM Number of**Ch~annel's** 

# 10 Control Transmission Distance/Rang,e (Optimum 

# Conditi!ons) FCC Complia,nce: Up to 

# 80·0m (2624.67 ft) 

# CE Compliance: 

# u:p to**40~0m (13~1**  

# .2.34 ft) 

# Robust Radio Control Modu1la.tion Yuneec 

# Protocol Video link

# Frequency Band**5~.8GHz** 

# Video 

# Transmission Distance/Range 

# (Optimum Conditions) FCC Complliance:**Up~** 

# to 600m (1968.5 ft) 

# CE Compliance: Up to 300m (984.252 ft) 

# Flight Systems Tel.emetry Daita 

# On Screen Display (OSD) 

# Yes LED B.acklit LCD Scr@en·**Ca~nacitive** 

# Multi-Touch