### 1 June 5, 2015 U. S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

Re: Section 333 of the FAA Reform Act of 2012

Dear Administrator,

I, Robert A. Carroll, herein refe rred 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, Robert A. Carroll, 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 UAS 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 Arizona and adjoining states utilizing a small unmanned aircraft system (s UAS) for aerial still and video data capture for, but not limited to the following purpose:

*Real Estate Sales *Residential/Commercial Roof inspections/Flare Stack inspections *Crop Inspection *Property Video Survey *Photo/Videography of rural contracted outdoor re creational activities on private and public use lands (Prior Permission and coordination Only) *Fire Survey and Rural Search Assist to local public and private entities.

Furthermore the petitioner is a member of the Academy of Model Aeronautics for 15 years, and warrants to conduct operations over private or public lands in the above uses with safety for the general public as the greatest priority. In addition, the safe integration of the UAS 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 person al injury and or death and extensive property damage.

The use of UAS could fulfill a service to consumers an d 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 manufactures model de signation Q500 Typho on. It is an advanced (sUAS) with state of the art safety featur es, 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 batte ry. Aircraft LED visual alert indi cators for low battery, GPS loss, and communication loss. The UAS has a first person view on the controller that is not to be used for flight by the PIC. The UAS has the ability to link with a smartphone or tablet for video link separate from the on board display if needed. The UAS has separate radio frequencies for telemetry and video downlink and

aircraft control. See the follo wing manufactures specifications.

Yu neec Q500 Typhoon, quad copter

Flight Time Up to 25 Minutes Height 240mm (9.45 in) Width 420mm (16.54 in) Diagonal Length W\O Rotor Blades  565mm (22.2 in)

### 2 Propeller/Main Rotor Diameter 330mm (13.0 in) Weight W/O and Payload 1130g (40.0 oz) Battery 5400mAh 3S 11.1V LiPo 3 Flight Modes Smart, Angle and Home Modes Maximum Flying Height Default 400 Feet AGL (Adjustable via the Q500 GUI) Maximum Rotational Velocity 65°/s Maximum Bank Angle 35° Maximum Climb Rate in Smart and Angle mode 3m/s Maximum Descent Rate in Smart and Angle mode 2m/s Takeoff Weight With Battery and CGO2-GB 1700g (60.0 oz ) Radio Control Frequency Band 2.4GHz Maximum Groundspeed 15 MPH

ST10 Personal Ground Station

Operating SystemAndroidTM

Number of Channels10 Control Transmission Distance/Range FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft)

Robust Radio Control Modula tion Yuneec Protocol Video link Frequency Band 5.8GHz Video Transmission Distance/Range (Optimum Conditions) FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft)

Warning: You Must Follow Local Laws and Maintain Vi sual Line of Sight of Aircraft at All Times.

Flight Systems Telemetry Data On Screen Display (OSD) Yes LED Backlit LCD Screen Capacitive Multi-Touch 4.5” Tactile (Vibrating) and Audible Feedback Yes Built-In LiPo Battery Voltage / Capacity 3.6V/5200mAh 18.72Wh

CGO2-GB Camera Gimbal System

Focusing System Aerial Optimized Fixed Focus

Video Field of View 130°

Transmission Band 5.8GHz Video Transmission Distance/Range FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) with ST10

UAS are often seen as superior to manned helicopters du e 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 w ith 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 Visu al 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 failsaf e-automated feature of retu rn to home in the event

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

In addition to the requirements already set forth by C.F.R. Title 14 and the applicable FAR, The petitioner

will-- a. Only operate its UAS in direct visual line of sight of the pilot and observer without use of a

### 3 visual aid other than corrective lenses. b. Operate at an altitude no greater than 400 feet above the ground. c. Operate with due vigilance and known practi ced see and avoid scanning techniques to avoid any conflicts with manned or other UAS aircraft that may enter the UAS operating area. The UAS flight will be immediately terminated if a potential conflict may exist. d. Operate over private or public sites only with prior permission from property owner or owner’s agent or legal authorities as allowed by law. e. Terminate flight when any unsafe condition exists. f. Terminate flight when battery voltage dr ops to 30% of battery capacity or when the 1 st low battery alert occurs per the Q500 Typhoon Instruction Manual, not to exceed 18 minutes run time. g. Operate at a ground speed of 0 to 15 mph during on site missions. h. Operate in accordance with the guidance an d standards set forth by the AMA, the UAS

manufacturer and the administrator. i. Operate with a minimum crew for each operation consisting of th e PIC and a visual observer in direct communication utilizing appropriate verbal, radio or cell phone as needed. j. Insure the sUAS operator on the controls will be at least a current Private Pilot with a class III

medical. k. Provide ground inst ruction with standards and content cu rrently accepted by the administrator for private pilot knowledge testing, to the observer and or UAS.

The petitioner requests exemption from 14 CFR pa rt 61.113 Private Pilot Privileges, Pilot in Command Section (a). In the Grant of Exemption No. 11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC operating th e Astraeus UAS would not adversely affect operations in the NAS or present a hazard to persons or property on the groun d. The petitioner requests the same consideration and limitations as previously granted.

Title 14 CFR part 91.7(a) Ci vil 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 curr ent and forecast weather, airspace, notams, area of operations, and notice issued to non-participating pers ons in local proximity. The petitioner will utilize the Yuneec, Q500 Instruction manual, qu ick start guide and the petitioners ow n pre-flight checklist included in the attached supplements to dete rmine 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 co mplete 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 pe rsons, property or vessel a pplied to previous grants of exemptions. The exemption is requested with the following conditions and limitations in conducting the petitioners operations—

### 4 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 th an 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-partic ipating 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 ar ea within 500 feet of the operation, informing of the time, location and safety hazards to pers ons or property, the no tice 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 safe ty zone is breeched, flight will be immediately terminated.

h. The sUAS will be operated over public rura l 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 Pa rt 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, sim ilar 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 cap acity voltage is reached. The UAS also provides 2 and

3 rd 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

1 st

low battery alert or no longer than 18 minutes wh ich 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 Su bpart E (§§ 91.401-417),) Maintenance required, 91.407(a)(1) Operation after main tenance, preventive maintenan ce, rebuilding, or alteration, 91.409(a)(1) and (2) Insp ections, and 91.417(a) an d (b) Maintenance records

. Currently the manufacturers maintenance procedures govern preflight with no limits other than on-condition. The petitioner will complete all authorized component replacem ents at the petitioner’s base of operations or in the field as required. The manufacturer or authoriz ed 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 shou ld provide an acceptable level of safety for the operations performed and is cons istent 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).

### 5 Sincerely,

Robert	A.	Carroll

7	Breeze	Hill	Ln Palm	Coast,	FL	32137

386‐446‐4467