UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Blake Michael Kosicek FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF TRAXXAS ATON and YUNEEC TYPHOON Q500 4K PROFESSIONAL M ANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on February 9 , 2016

Blake M. Kosicek W330N4352 Glen Parc Circle Nashotah, Wisconsin 53058

- 9550 (423) 305

- 54542 TABLE OF CONTENTS Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...................................................................................................................... .....4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND................ ....................................................................................................4

BASIS FOR PETITION.........................................................................................................5

NAME AND ADDRESS OF PETITIONER........................................................... ..............8

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH BLAKE MICHAEL KOSICEK SEEKS EXEMPTION.................................................................

....................... . 8

THE EXTENT OF RELIEF BLAKE MICHAEL KOSICEK SEEKS AND THE REASON BLAKE MICHAEL KOSICEK SEEKS THE RELIEF......................... ..........................12

THE REASONS WHY GRANTING BLAKE MICHAEL KOSICEK ’S REQUEST WOULD BE IN THE PUBLIC INTEREST ................

........................................ ............ . 16

THE REASONS WHY GRANTING THE EXEMPTION FOR BLAKE MICHAEL KOSICEK WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................

........................... .......................... 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..... .............35 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT BLAKE MICHAEL KOSICEK ’S REQUEST........ .........................................35

CONCLUSION................................................................................................................... .35

APPENDICES.................................................................................

... 37

- 383 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level AOI Area of Interest A TC Air Traffic Control ATO Air Traffic Organization AV Aerial Vehicle CFR Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SO Safety Observer SOP Standard Operating Procedures UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing4 SUMMARY

Blake Michael Kosicek seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of

the FAA Modernization and Reform Act of 201 2 (FMRA). This exemption will permit

Blake Michael Kosicek to operate an Unmanned Aircraft System (UAS) for the

commercial and residential purpose of conducting aerial video and photography of construction sites, real estate, and landscape over certain are as of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER Blake Michael Kosicek will provide his clients with highest quality digital content for use in commercial, personal, and multimedia projects. Blake Kosicek has eight years of expertise and knowledge in radio c ontrolled flight as well as four years of real estate insights

. Blake Mi chael Kosicek has hobby experience in nitro and electric radio controlled cars, helicopters, planes, b oats and quadcoptes for over eight years.

The objective of Blake Michael Kosicek ’s aerial video operation s is to provide high quality imaging for a variety of comme rcial, public, and residential uses, specifically targeting:

• Aerial acquisitions used for inspections of public and private infra structure

.

• Aerial video and photography for the Real Estate sector

• Increase public knowledge of UAS and promote safe UAS operations

• Search and Rescue operations

. BACKGROUND Unmanned Aircraft Systems: TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Professional UASs5 Blake Michael Kosicek seeks an exemption to operate TRAXXAS ATON and YUNEEC TYPHOON Q500 4K for compensation or hire within the NAS. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Grou nd Control Station (GCS) utilizing electronic tablet or smart phone systems.

The TRAXXAS ATON overall weight with landing gear is 860 grams , with

di mension of 218mm height x 472mm wide, and a maximum speed of approximately 50mph, 43.45 knots.

The YUNEEC TYPHOON Q500 4K overall weight with landing gear is 1700

grams, 210mm height x 420mm wide, and a maximum speed of approximately 22mph,

19.12 knots

. Both t he TRAXXAS ATON and the YUNEEC TYPHOON Q500 4K are equipped with four main rotors; driven by Lithium Polymer battery powered brushless electric

motors. TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs that will be operated by Blake Michael Kosicek are already registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

. Drone Registration # FA3KPE7X7L.

BASIS FOR PETITION Petitioner, Blake Michael Kosicek , pursuant to the provision s of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby6 petitions the Administrator to commercially operate TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideratio n of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, Blake Michael Kosicek ’s operation of TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Blake Michael Kosicek requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth

re quirements for maintenance that only apply to aircraft with an airworthiness certificate.

Blake Michael Kosicek submits that the requested relief is proper since an equivalent level of safety will be ensured. Blake Michael Kosicek will use experienced

per sonnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log , and TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Instruction Manual). Furthermore, Blake Michael Kosicek will

document and maintain all maintenance records for the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by Blake Michael Kosicek to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level7 certificate, as well as an airman medical certificate, and who has demonst rated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Blake Michael Kosicek seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness , because the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Blake Michael Kosicek submits that he will ensure that the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Instruction Manual), and that the aircraft are in a condition for safe flight.

Blake Michael K osicek also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs will not have a typical barometric altimeter onboard. However, altitude

information of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude informatio n, combined with Blake Michael

Kosicek’s operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.8 Additionally, Blake Michael Kosicek seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. Blake Michael

Kosicek submits that safety will not be affected by operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs during d aylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of appro ximately 10 .5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14 C.F.R. § 11.81, Blake Michael Kosicek provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner an d point of contact is:

Blake M. Kosicek W330N4352 Glen Parc Circle Nashotah, Wisconsin 53058

- 9550 (423) 305

- 5454 Email: 1AirborneDrone@Gmail.com B. The Spec ific Sections Of 14 C.F.R. From Which Blake Michael Kosicek Seeks Exemption.

1. Blake Michael Kosicek Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in command , subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A privat e pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and9 (2) The aircraft does not carry passengers or property for compensati on or hire.

2. Blake Michael Kosicek Seeks Exemption From The Requirements Of Section 91.7(a). Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airwo rthy condition.

3. Blake Michael Kosicek Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

-- (1) Below 18,000 feet MSL, to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

4. Blake Michael Kosicek Seeks Exemption From The Requirements Of Section 91.151(b).

S ection 91.151, entitled Fuel requirements for flight in VFR conditions , subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enoug h fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.10 5. Blake Michael Kosicek Seeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this secti on, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Blake Michael Kosicek Seeks Exemption From The Requirements Of Section 91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration , subsection (a)(1), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. Blake Michael Kosicek Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections , subsecti on (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter an d has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. Blake Michael Kosicek Seeks Exemption From Th e Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following:11 (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i ) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed o n the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances a re maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring ac tion, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or ope rator shall retain the following records for the periods prescribed:12 (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief Blake Michael Kosicek Seeks And The Reason Blake Michael Kosicek Seeks The Relief.

1. Extent Of Relief Blake Michael Kosicek Seeks And The Reason B lake Michael Kosicek Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or hig her level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the lim itations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, Blake Michael Kosicek submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the

TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS unless that PIC has met certain flight

- hour and currency requirements, demonstrating that the PIC is able to safely operate either the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS in a13 manner consistent with the operations specif ications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures. Further, Blake Michael Kosicek submits that all flights of the TRAXXAS ATON

and YUNEEC TYPHOON Q500 4K UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Blake Michael Kosicek’ s business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Blake Michael Kosicek Seeks And The Reason Blake Michael Kosicek Seeks Relief From Section 91.7(a). Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow Blake Michael Kosicek to determine that the TRAXXAS ATO N and YUNEEC TYPHOON Q500 4K UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Blake

Michael Kosicek Airborne Drone Operations Manual, Monthly Maintenance Log, and

TRAXXA S ATON and YUNEEC TYPHOON Q500 4K Instruction Manual).

Blake Michael Kosicek seeks the requested relief because the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. T herefore, Blake Michael Kosicek will

ensure that TRAXXAS ATON and YUNEEC TYPHOON Q500 4K the UASs are in airworthy condition based upon its compliance with the operating documents (i.e ., Monthly Maintenance Log, and TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Blake Michael Kosicek Seeks And The Reason Blake Michael Kosicek Se eks Relief From Section 91.121.14 Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any altitude informatio n concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL),

Blake Michael Kosicek seeks the requested relief because the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UA’s altimeter may be set on the ground to zero fee t AGL, rather than the local barometric pressure or field altitude, before each flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and

l imitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically

ensures th at a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief Blake Michael Kosicek Seeks And The Reason Blake Michael Kosicek Seeks Relief From Section 91.151(b). Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR

conditions , is requested to the extent required to allow flights of the battery powered TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs during day light hours in visual meteorological conditions (VMC), under visual flight rules ( VFR), for a total

duration of 10 .5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Blake Micha el Kosicek seeks the15 requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs will severely constrain the practicality of any aerial video or still pho to flight operations that Blake Michael Kosicek proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K operating documents, and Blake Michael Kosicek ’s proposed operating limitations, ensure that Blake Michael Kosicek will safely operate the battery powered TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power t o fly for a total duration of 10 .5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minutes.

5. Extent Of Re lief Blake Michael Kosicek Seeks And The Reason Blake Michael Kosicek Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Blake Michael Kosicek requests

relief from these Sections because the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs do not require airworthiness certificates. As set forth more fully below, the

TRAXXAS AT ON and YUNEEC TYPHOON Q500 4K UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Blake

Michael Kosicek will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Blake Michael Kosicek Airborne16 Drone Operations Manual, Monthly Maintenance Log, and TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Instruction Manual). Fu rthermore, Blake Michael

Kosicek will document and maintain all maintenance records for the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs. D. The Reasons Why Granting Blake Michael Kosicek ’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the public interest by allowing Blake

Michael Kosicek to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the

United States. Additionally, use of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K

UASs will decrease c ongestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Blake Michael Kosicek’s proposed operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will be realized without implicating any privac y issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS.

The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obt ain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.17 Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic

cont rol during the ground, takeoff, departure, arrival, and landing phases of flight operations. 2. The Public Will Benefit From The Safety And Efficiency Of The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs. Conducting aerial acquisitions with the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using batt ery power and electric motors,

the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically u tilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of leaded aviation

fuel. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise polluti on, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine. By using the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew18 members located onboard the aircraft, the TRAXXAS ATON and YUNEEC TYPH OON Q500 4K UAs (weighing 860 grams, 1700 grams respectively), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approxi mately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 3. Performing Aerial Video and Photography Operations With TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS s Will Benefit The Economy. In addition to being safe and efficient, the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UA Ss will allow United States based companies, like

Blake Michael Kosicek , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory acti ons phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs is one such technology that not on ly allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. By operating the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, companies suc h as Blake Michael Kosicek , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately19 contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order t o remain competitive both in the United States and abroad. 4. There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been conducted for decades, Blake Michael Kosicek ’s proposed operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will not implicate any privacy issues. Specifically,

the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will be operated only in compliance with operating documents (i.e., the Blake Michael Kosicek Airborn Drone Operations Manual , Monthly Maintenance Log, and TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. E. The Reasons Why Gra nting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Blake Michael Kosicek Seeks Exemption. 1. Reasons Why The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Blake Michael Kosicek ’s o peration of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.20 Section 333 provides authority for a UAS to operate wi thout airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in par t: (a) In General.

- - Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace s ystem before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. (b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is re quired for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national airspace system. In seeking this exemption, Blake Michael Kosicek submits that the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. a. The Specifications Of The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K U ASs Demonstrate Its Safe Characteristics.21 The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability. i. Technical Specifications Of The TRAXXAS ATON and YUNEEC

TYPHOON Q500 4K UA Ss

. The technical specifications of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Professional UASs are set forth by the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Specifications and Data Sheet, attached hereto as Exhibit A and B.

ii. The TRAXXAS ATON and YUNE EC TYPHOON Q500 4K UASs Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the TRAXXAS ATON and YUNEEC TYPHOON Q500

4K is provided at page 7 of the TRAXXAS ATON and page 15

- 19 of the YUNEEC

TYPHOON Q500 4K User Manuals, attached hereto as Exhibit C and D.

iii. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds,

the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs do not reacquire control link data from the GCS, t he UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown.22 A complete description of the Failsafe Functions of the TRAXXAS ATON UAS

ar e set forth at pages 7 and on page19 of the YUNEEC TYPHOON Q500 4K User Manuals, attached hereto as Exhibit C and D.

iv. The TRAXXAS ATON and YUNEEC TYPHOON Q500 4K GCS And Its Operation. A complete description of the operation and specifications of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K GCS and flight control software is provided at pages 4 through 10 of the TRAXXAS ATON User Manual and pages 3 through 24 of the YUNEEC TYPHOON Q500 4K User Manual. TRAXXAS ATON and YUNEEC TYPHOON Q500 4K User Manuals are attached hereto as Exhibits C and D. b. Flight Operations Of TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs Are Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. Blake Michael Kosicek will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs. Additionally, a safety observer will

assis t all pilots during flight time, however, under current law, a valid drivers license and valid drone certification code is all that is required and thus will be followed for current legal compliance for flying a microscopic vehicle c. Flights Of TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, Blake Michael Kosicek proposes to commercially operate TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs for the special purpose of conducting aerial video and ph otography over certain areas of United States, pursuant to the following specific operating limitations:23 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs wei ghing less than 55 pounds maximum gross weight: TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Professional Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no mo re than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 5. The UAs must be operated within vis ual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate. 6. The use of first person view (F PV) by the PIC or safety observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communi cate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO c an perform the functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the oper ating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its opera ting documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines24 that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (A FS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that af fects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspec tion. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipmen t, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must m ake an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate. 18. The oper ator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and eme rgency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are25 permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are consid ered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conduc ted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM a s required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 22. If the UA loses communications or loses its GPS signal, it must return to a pre

d etermined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning 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 25% battery power remaining. 25. The ope rator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements

. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.26 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirement s. 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement off icial upon request. 29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. Flight operations must be cond ucted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or s tructures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential p ersons do not present an undue hazard to those persons per § 91.119(a). 32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land own er/controller or authorized representative will be obtained for each flight to be conducted. 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA mus t be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.27 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely Affect Safety. Blake Michael Kosicek submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Blake Michael Kosicek’s proposed area of operations, and the operating limita tions set forth

- above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary to safely operate the TRAXXAS ATON and YUNEEC TYPHOON Q 500 4K UAS, Blake Michael Kosicek submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Blake Michael Kosicek ’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 1 1138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Blake Michael Kosicek will not allow any PIC to operate TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the TRAXXAS ATON a nd YUNEEC TYPHOON28 Q500 4K training and currency requirements, that the PIC is able to safely operate the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appro priate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exe mption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Blake Michael Kosicek ’s proposed operations. The

Administrator has held tha t prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and m odel of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and t he 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- ho ur requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in complia nce29 with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

- b uilding flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Blake Michael Kosicek will ensure safe operations by not allowing any PIC to operate the TR AXXAS ATON and YUNEEC TYPHOON Q500 4K UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS in a manner consistent with the exe mption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures. 3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect Safety. The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Blake Michael Kosicek will ensure that the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS is in an airw orthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and

limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 4. Reasons Why An Exemption From The Requiremen ts Of Section 91.121 Would Not Adversely Affect Safety.30 The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs will be provided to the PIC via GP S equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Blake Michael Kosicek ’s operation of the TRAXXAS ATON and YUN EEC TYPHOON Q500 4K UAs within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a z ero altitude initiation point is automatically established by the UASs at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemptio n Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety. A gran t of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs; (2) the limitations on the proposed flight operat ions; and (3) the location of the proposed flight operations. Accordingly, Blake Michael Kosicek will ensure that it will safely operate the battery powered TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAs during daylight hours in VFR conditions, with enough ba ttery power t o fly for a total duration of 10 .531 minutes to the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 4.5 minutes. Here, as in Exemption No. 11109, the technical specifications of the TRAXXAS

AT ON and YUNEEC TYPHOON Q500 4K UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as

the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will descend and land automatically. Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical charac teristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously g ranted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11 150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.32 In seeking this exemption, Blake Michael Kosicek submits that the equivalent level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be

met because Blake Michael Kosicek will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the Blake Michael Kosicek Airborne

Drone Operations Ma nual, Monthly Maintenance Log, and TRAXXAS ATON and YUNEEC TYPHOON Q500 4K Instruction Manual). Furthermore, Blake Michael

Kosicek will document and maintain all maintenance records for the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs.

Since the TRAXXAS A TON and YUNEEC TYPHOON Q500 4K UASs will be inspected as prescribed by the operating documents, Blake Michael Kosicek will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K User Manuals are attached hereto as Exhibit C and D; a copy of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UAS Maintenance LOG is attached hereto as Exhibit E. Likewise, the exemption sought will not adversely affect safety bec ause Blake

Michael Kosicek will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents. Furthermore, the exemption sought would ma intain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs will be performed by33 trained technicians. Maintenance will be documented and maintaine d utilizing the monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical chara cteristics and operating limitations of the

UAS are considered.

In consideration of Blake Michael Kosicek ’s proposed operating limitations, the operating documents, and the technical aspects of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, Blake Michael Kosicek submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circums tances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions , Blake Michael Kosicek requests that the FAA prescribe special conditions for the intended operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F .R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose of34 conducting aerial video and photography over c ertain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, pro vides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuan t to 14 C.F.R. § 21.16, for operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions , states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller becau se of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such sa fety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent t o that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).35 F. A Summary That Can Be Published In The Federal Register, stating: T he Rules From Which Blake Michael Kosicek Seeks Exemption:

Blake Michael Kosicek seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). A Brief Description Of The Nature Of The Exemption Blake Michael Kosicek Seeks: This exemption will permit Blake Michael Kosicek to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and photography over cer tain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support Blake Michael Kosicek ’s Request. This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Blake Michael Kosicek ’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthines s certification. As discussed in detail above, Blake Michael Kosicek will operate the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION As set forth herein, Blake Michael Kosicek seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 o f the FAA Modernization and Reform Act of 201236 (FMRA), which will permit safe operation of the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K U ASs commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photograp hy over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Blake M ichael Kosicek to safely, efficiently, and economically operate the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Blake Michael Kosicek respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the TRAXXAS ATON and YUNEEC TYPHOON Q500 4K UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Date d: February 9 , 2016

Respec tfully submitted, 

# Blake Michael Kosicek

_________________________ Blake Michael Kosicek W330N4352 Glen Parc Circle Nashotah, Wisconsin 53058

- 9550 (423) 305

- 545437 Appendices :

A

– Traxxas Aton Specifications Data Sheet B

– Yuneec Typhoon Q500 4K Specifications Data Sheet C

– Traxxas Aton Manufacturer’s User Manual D

– Yuneec Typhoon Q500 4K Manufacturer’s User Manual E

– Monthly Maintenance Log

APPENDIX

– A

TRAXXAS ATON TECHNICAL SPECIFICATIONS

Blake Michael Kosicek only util izes safe and reliable UASs. TRAXXAS is an industry lea der in small UAS production. TRAXXAS UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can als o be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined and set distance. In addition, TRAXXAS software provides real

- time altitude and location information to the PIC via the linked monitor (s mart phone/tablet devices)

1.1 TRAXXAS ATON See User Manual

A PPENDIX

– B YUNEEC TYPHOON Q500 4K TECHNICAL SPECIFICATIONS

Blake Michael Kosicek only utilizes safe and reliable UASs. Yuneec is an industry lea der in small UAS production. Yuneec UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit f l ight to a predetermined an d set distance. In addition, Yuneec software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

2.2 Yuneec Typhoon Q500 4K See User Manual

A PENDIX

– C38 Traxxas Aton Manufacturer’s User Manual

D owload User Manual

- https://traxxas.com/sites/default/files/KC2363

- R02

- Aton

Owners

- Manual_EN.pdf

A PPENDIX

– D Yuneec Typhoon Q500 4 K Professional Manufacturer’s User Manual

D owload User Manual

- https://www.yuneec.com/download/manuals/q500_4k_user_manual.pdf

APPENDIX

– E