June 4, 2015

U. S. Department of Transportation

Federal Aviation Administration

Docket Management System

Washington, DC 20590

Re: Section 333 of the FAA Reform Act of 2012

Dear Administrator,

I, Charles Kennett, herein referred to as (the petitioner), am writing pursuant to the FAA Modernization

and Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that the petitioner,

Charles Kennett, an owner and operator of a small unmanned aircraft system (sUAS), petition for

exemption from the Federal Aviation Regulations listed below and any regulation as required by the FAA

that is deemed necessary in order to conduct commercial sUAS operations as described.

The requested exemption would permit the petitioner to pursue, safe, professional, for profit services to

private and public entities within the State of Texas and adjoining states utilizing a small unmanned

aircraft system (sUAS) for aerial still and video data capture for, but not limited to the following purpose:

*Property Video Survey

*Residential/Commercial Roof inspections/Flare Stack inspections

*Crop Inspection

*Real Estate Marketing/Sales

*Photo/Videography of rural contracted outdoor recreational activities on private and public use lands

(Prior Permission and coordination Only)

*Fire Survey and Rural Search Assist to local public and private entities.

*Golf Course Marketing and Survey

INTRODUCTION AND INTERESTS OF THE PETITIONER

Charles Kennett provides his clients with expertise and knowledge in advanced technologies and solutions to increase 

efficiency, productivity and effectiveness. Charles Kennett has hundreds of hours flying experience. He has over 10 years

recreational/hobby experience in all aspects of aerial video and photography. In addition, the safe integration of the sUAS into 

the national airspace without interference or hazard to manned aircraft is of utmost importance. The proposed

services are offered with the intent of enhancing the development and safe operation of unmanned aircraft

systems, realizing that current manned aircraft operations pose a much greater risk of personal injury and/or

death and extensive property damage. The use of sUAS could fulfill a service to consumers and small

entities that would otherwise not exist due to the risks and costs involved with manned aircraft.

The initial (sUAS) to be utilized during the operations is a consumer class helicopter, quad-rotor aircraft. It is manufactured by 

Yuneec, Inc. and has the manufacturer’s model designation Q500+ Typhoon. It is an advanced (sUAS) with state of the art safety 

features, GPS lock, altitude, position hold stabilization, smart mode, angle mode follow me and return to home mode. The 

ground station has telemetry with altitude, groundspeed, GPS location and battery life for both, the transmitter and aircraft as 

well as an audible and vibration alert for aircraft low battery as well as LED visual alert indicators for low battery, GPS loss, and 

communication loss. The sUAS has a first person view on the controller that is not to be used for flight by the PIC. The sUAS has 

the ability to link with a smartphone or tablet for video link separate from the on 2 board display if needed. The sUAS has 

separate radio frequencies for telemetry and video downlink and aircraft control. See the following manufacturer’s 

specifications.
TYPHOON Q500+

Height: 210mm (8.3 in)

Length (without rotor blades): 420mm (16.5 in)

Width (without rotor blades): 420mm (16.5 in)

Diameter (without rotor blades): 565mm (22.2 in)

Propeller/Rotor Blade Diameter: 330mm (13.0 in)

Weight (without battery and payload): 1130g (40.0 oz)

Takeoff Weight (with battery and CGO2+): 1700g (60.0 oz)

Battery: 5400mAh 3S 11.1V LiPo (included)

Charger: DC 3S 11.1V LiPo balancing and AC adapter

Transmitter: ST10+ 10-channel 2.4GHz with 5.8GHz video link (included)

Flight Time: 20-25 minutes

CGO2+ Camera

Height: 115mm (4.5 in)

Width: 75mm (2.9 in)

Depth: 135mm (1.4 in)

Weight: 185g (6.5 oz)

Video Resolution: 1080p 60, 50 or 48 fps

Photo Resolution: 16 megapixels

Transmission Distance/Range: Up to 600m (1970 ft) depending on receiving device and 

environment

Transmission Band: 5.8GHz

Storage (memory): Micro SD Class 10 up to 128GB

ST10+ Personal Ground Station

Number of Channels: 10

RC Band: 2.4GHz

RC Modulation: Yuneec

Video Downlink Band: 5.8GHz

Telemetry/OSD: Yes

SD Card Compatible: Yes

LCD Screen Size: 5.5”

Touchscreen: Yes

sUAS are often seen as superior to manned helicopters due to the smaller size and lower costs, reduced noise

and as such, a much smaller environmental and safety impact.

The petitioner requests exemption to operate a Yuneec, Q500+ Typhoon equipped with a three-axis CGO2+

Gimbal and Camera, both products of Yuneec. This sUAS has a pre-programmed limit for the altitude

above ground level at 400 feet and a Geo fence while in Smart Mode with a distance limit of 300 feet from 

the controller. These limits are preset at the factory and will be kept at those limits, which currently

comply with the AMA’s and FAA requirement for Visual Line of Sight limitation and an AGL limitation.
The ground station is also programmed with a safety feature that disables motor start up if within Class B,

and C airspace boundaries. The Q500+ also has the failsafe-automated feature of return to home in the event

that communication is lost between the ground station and the aircraft.

The petitioner requests exemption from 14 CFR part 61.113 Private Pilot Privileges, Pilot in

Command Section (a). Although the petitioner is a current certified commercial pilot the petitioner may

elect to utilize certified private pilots with class III medicals to conduct operations with the sUAS. In the

Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with a private

pilot certificate operating the Astraeus UAS would not adversely affect operations in the NAS or present a

hazard to persons or property on the ground. The petitioner requests the same consideration and limitations

as previously granted.

Title 14 CFR part 91.7(a) Civil Aircraft Airworthiness. As no Airworthiness Certificate is available for

this sUAS the petitioner requests exemption under this part utilizing a preflight inspection and the

manufacturers documents for determining compliance of the sUAS airworthiness. The petitioner warrants

compliance to part 91.7(b) in that the operation will only be conducted after a thorough preflight and premission

planning inspection is completed, to include current and forecast weather, airspace, notams, area of

operations, and notice issued to non-participating persons in local proximity. The petitioner will utilize the

Yuneec, Q500+ Instruction manual, quick start guide and the petitioners own pre-flight checklist included in

the attached supplements to determine the sUAS airworthiness.

The petitioner requests exemption from 14 CFR part 91.119(c) Minimum Safe Altitudes.

The petitioner requests exemption from Section (c) with the following conditions and limitations. The

petitioner requests the exemption due to the scope of the operations to be performed and the requirement to

operate below 400 feet AGL. The Petitioners primary mission would be to record data or survey of

persons, property or structures as listed above. The sUAS size, weight, speed and limited operating times

and area, as well as the soft materials used in the construction of the sUAS, would provide an equivalent or

greater level of safety as intended under this part.

The Q500+ is a helicopter as defined by CFR Title 14, FAR Part 1, general definitions. The sUAS has a 

vertical to near vertical descent in the event of a power failure. Fly-a-ways would be the greatest or most

dangerous risk to non-participating persons. The Q500+ has no documented (fly-away), while operated

under GPS lock within the parameters of the Q500+ operating instructions. The Q500+ is a very stable, low

rotor speed sUAS that maneuvers, under GPS lock, relatively slow compared to similar sized UAS. In an

emergency the sUAS would be quickly brought down per the loss of control procedure as described in the

emergency procedures checklist, adequate time to complete the procedure would exist due to the 0 to 15

mph operational groundspeed of the Q500+. The risk to persons 100 feet away would be at no greater risk

than persons located 500 feet away. The petitioner requests exemption from the 500-foot altitude

restriction and the 500-foot stand off restriction from persons, property or vessel applied to previous grants

of exemptions. 
The exemption is requested with the following conditions and limitations in conducting the

petitioners operations—

a. The sUAS will be operated at an altitude of no more than 400 feet above ground level.

b. The sUAS will not be operated at greater than a 400-foot slant distance from the PIC.

c. The sUAS will not be operated over any non-participating person.

d. The sUAS will not be operated over a non-participating property, structure or vessel without

prior permission from the property owner or legal representative.

e. The sUAS will maintain a minimum slant distance of 100 feet from any non-participating

person and will increase the distance proportionally by 50 ft. per 50 ft. of altitude. At no time

will the sUAS be operated closer than a 100-foot slant distance to a non-participating person

unless that person is behind a protective barrier or shielded from possible debris in the event

of a crash.

f. A minimum of 2 hour notice will be distributed to all residences or businesses of a scheduled

operation in an urban business or residential area within 500 feet of the operation, informing

of the time, location and safety hazards to persons or property, the notice will include a phone

number to voice objections or concerns.

g. Warning signs will be displayed on the perimeter of the safety zone to alert passers-by of the

hazard and warning to stay back and behind cover. If the safety zone is breeched, flight will

be immediately terminated.

h. The sUAS will be operated over public rural lands with the same stand off distance and

altitude restrictions afforded persons, property and vessels per e. above.

The petitioner requests exemption from 14 CFR Part 91.121, Altimeter settings. The UAS will not

have a typical barometric altimeter onboard the aircraft, the petitioner intends to operate the UA within

VLOS and at or below 400 feet AGL, combined with the petitioner’s intention to limit the altitude of the

UAS through flight limit function on the UAS, has been previously ruled to be a sufficient method for

ensuring the UAS operations do not adversely affect safety. The altitude information will be generated by

GPS equipment installed onboard the aircraft, and/or a static pressure sensor (barometer), which aids in

estimating the altitude.

The petitioner requests exemption from 14 CFR Part 91.151, Fuel requirements for flight in VFR

conditions, prior relief has been granted for manned aircraft to operate at less than the prescribed

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has

been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, Visual Flight Rules (VFR)

conditions. The petitioner’s UAS provides low battery warnings that indicate the PIC must command the

UA’s return to the launch point when low battery capacity voltage is reached. The UAS also provides 2 and

3rd increased intensity critical low battery warnings through audio and vibration indicating that the UA

must be landed immediately, additionally a fail safe automatic landing will occur when the battery is at

absolute critical low voltage. The petitioner warrants that the sUAS will be landed immediately upon the

1st low battery alert or no longer than 18 minutes which ever occurs first. The petitioner will not initiate a
flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal

cruising speed to the intended landing point and land the UA with 30% battery power remaining.

The petitioner requests exemption from 14 CFR Subpart E (§§ 91.401-417),) Maintenance required,

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

91.409(a)(1) and (2) Inspections, and 91.417(a) and (b) Maintenance records. Currently the

manufacturers maintenance procedures govern preflight with no limits other than on-condition. The

petitioner will complete all authorized component replacements at the petitioner’s base of operations or in

the field as required. The manufacturer or authorized repair center will complete any maintenance or

repairs that cannot be completed by the petitioner. The petitioner warrants that preflight, post flight and

maintenance procedures set forth in the petitioner’s supplements attached should provide an acceptable

level of safety for the operations performed and is consistent with those of previous grants. In addition the

petitioner will comply with any and all manufacturers updates for UAS and Ground station as well as any

FAA directives and guidelines. An appropriate aircraft/maintenance logbook will be kept with the sUAS

ground station and base of operations as required, (See Supplement).

Sincerely,

Charles Kennett

8625 Hickory St. Apt 1221

Frisco, TX 75034

602-909-4438