Re: Exemption Request Pursuant To Section 333 of th e FAA Reform Act of 2012

Dear Sir or Madam, Pursuant to §333 of the FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, QCRD .LLC , operator of Small Unmanned Aircraft Sy stem s (sUASs) equipped to conduct aerial photography for the media and advertising industries for pre

- planned, controlled area, photographic and surveying services, hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow co mmercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as
may be established by

the Federa l Aviation Administration (FAA) as required by §333. QCRD 's
current operation of sUASs for commercial purposes has been halted to comply with recently enacte d federal aviation regu l ations pertaining to sUASs. As described more fu ll y below , the requested exemption woul d permit the operation of small, unmanned and re l ative l y inexpensive multi

- rotor airc raft under controlled conditions in airspace that is 1) contained 2) predetermined 3) has on

- s ite safety personnel controlling access, and 4) wou l d provide increased safety and enhancements to clients' business operations. The name and address of the appli cant is: QCRD .LLC Attn: Dana Rukse Ph: + l

- ( 724 )

- 237

- 2139 Em ai l: Drukse@comcast.net Address: 46 Cherokee Drive, Greensburg OA, 15601 QCRD .LLC respectfully

requests a grant of an exemption of the following sections of Title 14 of the Code of Federal Regulations:
**o** 14 CFR 21; **o** 14 CFR 91, et seq.; **o** 14 CFR 45.23 (b); Addr: 46 Cherokee Drive, Greensburg PA 15601 Ph: + 1

- ( 724 )

- 2 37

- 2139 Em ail: Drukse@comcast.net Web: Danaruksephoto.com
Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 • 14 CFR 61.113 (a) & (b); 14 CFR 407 (a)(l); 14 CFR 409 (a)(2); • 14CFR417(a)&(b). QCRD also respectfully

requests an Exemption from Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from:

• 14 CFR 45.23(b); 14 CFR Part 2 1; 14 CFR 61.1 1 3 (a) & (b); 91.7 (a); 91.9(b)(2);91.103(b);

•

•

• •• • 91.109; • 91.119; • 91.12 1 ; • 91.151(a); • 91.203(a) & (b); • 91.405 (a);
• 91.407 (a) (1); • 91.409 (a) (2); • 91.417 (a) & (b). I

. T he Ext e nt of Re l ie f QCRD .LLC S e e k s and th e Re aso n I t Seeks Suc h Re li e f : QCRD submits this application in accordance with the R efo rm Act, 112 P.L. 95 §§331

- 334, seeking relief from any currently applicable federal aviation regulations PARs pertaining toUASs (unmanned aircraft sy stems) and operating to p revent QCRD contemplated commercial

photography , Photographic mapping, and other flight operations within the U.S. nationa l airspace sy stem. The Reform Act in §332 provides for such integration of civil UASs into our national airspace sy stem as it is in th e public's interest to do so. QCRD 's lightweight UASs meet the definition of "small unmanned aircraft" as set forth in §331 and combined with a sterling safety record in similar industri es, QCRD 's light duty UASs are ideal recipients of exemption by the intent of the Reform Act. Considerations for relief include a combination of sUAS phy sical characte ri stics, safety features, and safe practices identified in §333:
• sUAS weight, • sUAS overall size, • sUAS speed over ground,
• sUAS flight zone characteristics,

- Non

- operation near airports (civilian or military),

- Tightly contro lled operation in populated areas,

the cl i ent. Spec i fic co n side rati on is outline belo w

. Re: Exemption R equest Pursuant To Section 333 of the FAA R eform Act of201 2
• Operation of the UAS by VLOS. • Coordinatio n by a minimum of 2 persons, 2 staff
me mbers of QCRD and one safety official from 1 4 C.F.R. Part 2 1 , Sub p art H : A i rworthin ess Ce rti fi cat es 14 C.F. R . §91.203 (a) ( 1) Subpart H, entitled Airworthiness Certificates, establishes the procedural r e quirem e nt s for th e issuance of airworthiness certificate s as requir ed by F AR §91.203 (a) (1 )

. Given the size and limit e d ope ratin g area associated sUASs, an exemption from Part 21 Subpart H m ee t s the requirem e nts of an e quival e nt l evel of safety under Part 11 and §333 of th e Refo rm A c t. 1l1e Federal Aviation Act (49 U.S.C.§4470 1 (f)) and §333 of the Reform Act bo th authorize the FAA to exempt aircra ft from the requirement for an airworthiness c e rtificate, upon consideration of the size, w e i ght, speed, operational capability , and proximity to airports and populated areas of the particu l ar sUAS. In all cases, an ana l ysis of these criteria demonstrat es that th e UAS operated without an airworthiness certific ate , in the r es tricted environment and under the conditions proposed will be at least as safe, or safer, than a conve ntional aircraft (fixed wing or rotorcraft) operating with an airworthiness certific at e without the restrictions and conditions proposed. The sUAS to be operated by QCRD is les s than 11kg. with maximal payload consisting of remote se n sing instrumentation, carr i es neither no per sons, carries no explosive or flammable mat e rial s including co mb ustib l e fuels, and operates exclusively wi thin a secured area. Unlike other civil airc raft , operations under this exemption will be tightly controlled and monitored by both the pilot (P I C), 'spotter' role designated to act as both the remote sensing controller and secondary monitor for safety i ssues, and a technician, which assists in matters r elated to maintaining the sUAS and also m onitors for sa fety c oncern s and liaisons to the on

- s it e safety

officials. These enhancements to current safety practices an d regulations, which already apply to civ il aircraft, provide a greater degree of safety to the public and property owners than conventional aircraft operation s conducte d with airworthiness certificates issued under 14 C.F .R. Part 21, Subpart H . Lastly , ap plication of these same crite ria demonstrates that there is no intrin s i c cre dibl e threat to national security po se d by the UAS, due to its size, s peed of operation, lo cation of operation, l ack of intrinsic exp l osive materials orflammable liquid fuels, and inability to carry a substantial exte rn a l load. 1 4 C.F.R. §45.23 (b ). Marking of th e Airc raft The regulation r e quir es: When marks include only th e Roman capit a l l e tt e r "N" and the registration number is displayed on limit e d , re strict e d or light

- sport cat egory aircraft or exp erim e ntal or provisiona ll y certificat e d aircraft, the operator must a l so display on that aircraft n ear eac h e ntran ce to th e cabin , cockpit, or pilot station, in l ette r s n ot l ess than 2 in c h es nor more than 6 inch es high, the words " limit ed ; ' "restricted;' "light

- sport;' "expe rim enta l ;' or "provisional;' as applicable. Even though the sUAS will have no airworthiness certificate, an exe mpti on may be n ee ded as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experim enta l " can be placed. G i ven the size of the sUAS, two

- inch lettering will be impossible. The wo rd "Expe rim ental" will be placed on the frame in compliance wi th §45.29 (f) at a size suitable for the available space. The equivalent level of s afety will be provided by

having the sUAS marked on its fuselage as required by §45.29 ( f) where the pilot, observer and other s working with the sUAV will see the identification of the UAS as "Expe ri mental." The FAA has issued the following exe mpti ons to this regulation to Exemptions Nos. 10700, 8738, 101 67 and 101 67A. Further m arkings includ e the use of flashing green LED illumination on the underside of the sUAS frame which s tand s at co ntra st against a blue or white sky. Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 14 C.P. R. §6 1.11 3 (a) & (b): Private Pilot Pri v il eges and Limitations: Pilot in Command. §61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry

a pilot or passengers, th e proposed ope rations can achieve the equivalent lev el of safety

of current operations by

requiring a ground crew member to have a private pilot's license rather than a comme rcial pilot's lic ense to operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no persons on board. The area of operation is contro lled and restricted, and all flights are planned and coordinated in advance

. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allow ing operations as requested with a private pilot in the ground crew exceeds the present l evel of safety achieved by

14 C.P.R. §61.1 1 3 (a) & (b). 1 4 C.P.R. §91.7(a): C ivil aircraft airworthiness. The regulation requires that no person may operate a civil a ircraft unl ess it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and th e requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, a subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be provided. 14 C.F.R. §91.9 (b) (2): C i v il Airc raft Flight Manual in th e Aircraft. §91.9 (b) (2) provides: No person may

operate a U.S.

- registered civil aircraft ... (2) For which an Airplane or Rotorcraft F light Manual is not required by §21.5 of this chapter, unles s th e r e is available in the aircraft a current approved airp l ane or Rotorcraft F li ght Manual, approved manual material, markings, and p l acards, or any combination thereof. The sUAS, given its size and configuration has no ability to carry a phy sical flight manual on the aircraft. The equival ent level of safety will be maintained by keeping the flight manual atthe ground control point where the pilot flying the sUAS will have immediate access to it. The

FAA has issued the following exemptions to this regulation: Exemption Nos. 8607,8737,8738, 9299, 9299A, 9565,95658, 10167, 10167A, 10602,32827, and 10700. 14 C.F.R. §9 1.10 3: Preflight action This regulation requires each PIC to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not b e provided for the aircraft an exemption will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and airc raft performance data before initiation of flight. Further, we have proprietary manuals
c r eated with the help of sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work with these organizations to ensure best safe practices are adhered to. 14 C.P.R. §91.1 09: Flight in s truction §91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and remotely piloted aircraft, by their design do not have fully

functional dual controls. Flight control is accomp l ished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual contro ls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraf t and by the size and

Re: Exemption R equest Pursuant To Section 333 of the FAA Ref o rm Act of2012 speed of the aircraft. Enhancing this safety is the t echnology inh ere nt in the remote controls utilizing digital communi cati on s wh i ch is paired to the sUAS m aking i t n early impossib le to unintentionally

or intentionally h ave the contr ol commun i cations interrupted. 1 4 C.F.R. §9 1.119 : M in imum safe altitudes §91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be operated at less than the minimum s prescribed, provided the person operating the h e li co pt er complies with any route or alti tudes prescribed for helicopters by the FAA. As this exe mpti o n is for a sUAS that closely mimic s the behavior of a h elicopter, and the exemption reque sts authority t o operate at altitudes up to 400 AG L, an exemption may be needed to allow such operations. As se t forth herein, th e UAS will never operate at higher than 400 AGL or b eyo nd unaided visual line of sight, whichever i s closer. It will however be operated in a r es trict e d area with sec urity officials tasked with ensuring pub l i c sa f

e ty , and where buildings and people will not be exposed to operations without their pre

- o btained consent and training. The equival e nt l e vel of safety w ill be achieved given th e size, weight, speed of th e UAS as well as the location wh e r e it i s o p erated . No flight operation will be take n without th e permission of th e property

owner in the case of private prope rty o r loc a l officials i the case of public prope rty or private property

with public inter ests. B ecau se of th e a dvanc e notice to the property owner and participants in the remote sensing activ ity , all affected individu a l s will be aware of the planned flight operations. Compared t o flight operations with aircraft o r rotorcraft weightingfar more than the maximum 11kg of QCRD 's sUASs proposed herein and the lack of

flammable fuel, any

risk associ ate d with these operations i s far l ess than those presently pre se nt ed with conventiona l ai rcraft operating at or below 500 AGL. I n addition, the low

altit ud e operations of the sUAS will e n sure separation between these s mall

- UAS operations and the operatio ns of conventiona l aircraft that must comply with §91.119. 14 C.F. R

. § 91. 1 21 Altime t er Settings §91.121 requires eac h person operating an aircraft to maint ain cruis in g a ltitud e by r efe rence to an alti meter that is set " ...to the e l evati on of the departure airport or an appropri ate a ltim ete r setting available befor e d eparture." A s th e sUAS
may not have a barometric altimeter, but instead a GPS altitude read out, an exemption m ay be
ne e d e d

. An equiva lent lev e l of safety wi ll b e achieved by th e operator, conf irming the altitud e of th e launch s ite s h own on the GPS altitude indicator b efo r e flight. The PIC and Technician will also ensure effective pairing with multiple GPS sources to guarantee accurat e dete c tion of height. 14 C.F.R. §9 1.15l (a): Fue l Requirements for Flight in VFR Conditions §9 1.1 5 1 (a) prohibits
an individual from beginning "a flight in an airp l an e und er VFR conditions unl ess (considering wind an d fo r ecast weather conditions) there i s enough fuel to fly to the first point of int e nd ed landing, and, assuming normal cruising speed

- (1) During the d ay , to fly after that for at least 30 minut es; or (2) At night, to fly after that for at l east 45 minutes:' The batt ery powering the sUAS provides approximately 15 minutes of powered flight i n hover mo de with out payload. QCRD 's sUAS will not be able to meet the 30 minute r eserve r equirement in 14 CPR §9 1.15 1. Operating the small UAS, in a tightly controlled area where on l y people and property owners or official representatives who have s i gned wa i vers will be allowe d , with less than 30 minutes of r eserve powe r , does not enge nd e r the ty

pe of risks that Sectio n 9l.l51(a) was intended t o alleviate give n the size and speed of the s mall UAS. QCRD believes that an equivalent level of safety can be achieved by lim iting flights to » 10 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS toils planned landing zone from any where in its limit ed o p e ratin g ar ea

. Similar exe mption s h ave been granted to other operation s, includin g E x em

ptions 2689F, 5745, 10673 , and

10808. Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 1 4 C.P. R . §9 1. 2 0 3 (a) & (b): Carryin g C i v il A ircraft Certi ficati on and Reg i stration The regulation provides in pertinent part: (a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate

. .. (b) No person may operate a civi l aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91. 715 is displaye d at the cabin or cockpit entrance so that it is legible to passengers or crew. The sUAS fully

loaded weighs no more than llkg and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS

. An equivalent level of safety wi ll be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access tothem, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions

to this regulation. A representative sample of oth er exceptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 1 4 C.P. R. §9 1. 405 (a); 4 0 7 (a) ( 1 ); 4 0 9 (a) (2); 4 1 7(a) & (b ): Mai nt e n an ce Ins p ecti o n s These regulations require that an aircraft operator or owner "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 section, have discrepancies repaired as prescribed in part 43 of this chapter

. .. ;' and others shall inspect o r m aintain the aircraft in compliance with Part 43

. Given that these section and Part 43 apply

only to aircraft with an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual. An equivalent level of safety will be achieved because these sma ll UASs are very limited in size and will carry

a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in working order prior to in i tiating flight, perform required maintenance, and keep a log of any m aintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to ma intain the aircraft in an airworthy condition to provide the equiva l ent level of safety

. An exemption granted to QCRD wou l d permit its operation of lightweight, unmanned, remotely controlled, sUA Ss in a tightly controlled environment with limited airspace. QCRD utilizes local business' safety officers in specifically determ i ned areas (designed flight zone) to mitigate injury and property damage while fulfilling clients' goa l s. Technical enhancements to current safety

controls will allow QCRD to operate exceeding current safety specifications, and stay ahead of, or meet, new ones being imp l em ented by the FAA and Department of Transportation. Further, QCRD conducts its operations in compliance with p rotocols described here i n or as otherwise established by the FAA. II. C o m me rci a l and Publi c Benefit s We at QCRD believe that granting this exemption request furthers the public interest by providing safe (by way of an unmanned sy stem) and efficient means t o meet technical problems so lvable by

elevated data collection instruments. QCRD client base are ty pically small to medium sized business' looking to increase their awareness of structures or landscape
on their respective properties through data collection other Public Interest aerial videography for geographical awareness and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

- prohibitive. Granting this exemption to the petitioner would allow him to provide this service at a much lower cost. Further, the petitioner indicates his small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larg er manned aircraft. The petitioner also states that the operation of his UAS will minimize ecological damage and promote economic growth b y providing information to companies looking to relocate or build in the Orlando metro area.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 by photographic, video graphic or lidar based s urve ying. By mo ving these functions onto sUA Sbase d a ircraft, the potential for l oss of life or prop e rty i s diminished due to the g r eater contr o l in a smal ler and safe r aircraft that holds no persons. Second, th ere are n o r eac tiv e or combustible mat e rial s on board the sUAS and thus the pot e nti a l for fire or explosions i s greatly diminished. Third , the s mall size and extreme man euverability of QCRD UASs allow the PIC to avo i d hazards. Lastly , du e to the natur e of the remot e se nsing instrumentation onbo ard, the sUAS can maint a in quite a safe dis t ance between the aircraft and the objec t (s) undergoing
sc rutiny. Acco rdingly , QCRD 's UASs have operated and will continue to operate at and above current safety levels. A

. The c os t s and b enefits of your propo s ed a ct i on t o socie ty i n general and s p eci fi c gro up s wi th i n s ociety A s d escribed above, QCRD 's past customers hav e been s m a ll to medium bus i ness seeki ng a remote se n s in g solution to specific issu es before a l arge r effort on th e ir part would com e und e rway. The impact to society , financial and otherwise, would be extr em ely minimal. In d eed, it's bee n demonstrated th at sUASs have the abi lity t o drastically increase the i nf o rmation available to polic ymakers at a frac ti on of the cos t of measurin g th i s d ata by terrestrial m ean s. One s uch impact would be inconvenience to directly proximal and non

- esse nti a l p e r s onne l that wou l d b e displaced from public or busin ess owned p roperty if it is d ee med to be unsafe. In this case we relay our needs for a f1ight zone with the r e quir e m ent that i t be safe from casual intrusions and allow the business time to sh ift operations in order to mi nimize potential safety issues. This is best perform ed with the aid of safety p erso nne l that actively steer n o n
- essenti al persons around th e flight zone

. 1

. T h e e ffe ct of an exem

p tio n f o r QCRD o n th e qua l ity o f the n atural and socia l e nvi ro nments Utilizing sUASs minimizes the requirement for c onventiona l a irc raft. Th i s eliminates the need for an onboard pilot, time consumin g adherence to regulations s urroundin g bookkeeping and
s ubmi ss ion of fli ght path s to l ocal civilian or milit ary airports, and detrim e ntal effec ts to the environment caused by operating a co mbustib l e fuel bas e d, l arge sca le aircraft, with r es tri cti ons on the proximity

to the targ e t for remote sensing. Ill. F l i ght Capabi l iti e s an d Ch ara c t eris ti c s of QCRD 's UAS s Persuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by

the overall capabilities and 1 characteristics of the sUAS. QCRD UAS s utili zes four (4) counter

- rotating propellers paired oppositely to each other for balance, control and st ability

. The total s pan of the sUAS i s less than ""'1.2 m a ll owing for stab l e flight
or l anding even with the sudden onset of d etrim e ntal e nv i ronmenta l conditions. The sUAS's hav e a maxima l un i t+ payload ma ss of 11kg, including cinematic/photographic or oth er surve yi ng e quipment. QCRD 's sUAS is designed to prim arily hover in place to cap tur e photographic data and then operate at l ess than a 35 knot maximum s p eed to th e n n ext point of interest. The y are capable of verti cal and horizontal operations but, in practice, is operated only
w i thin unaided VLOS of the PIC. In addition to the PIC, QCRD em ploy s a spotter (VOS role) and a technician (secondary VOS and on

- site personnel liaison) which are within unaided verbal communication range. These per so nn el ar e suppl eme nted by safety officials provided by the client who ar e instructed t o cordon 1 More characteristics have been outl in ed in the enclosed supp l ement al materials.Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012

off and otherwise minimize pedestrian access in the flight zone of the client's grounds. In the event of loss of visua l of the UAS, the PIC can change flight controls from cartesian (X,Y,Z) based controls to radial (r, a ,h) based controls which a ll ows the PIC to utilize on e controller axis to recall the VAS to the PIC's position without concern to the curr ent heading of the sUAS. In the event of loss of sight of the sUAS into an area co nt a ining hazards or possible hazards, the spotter ha s a heads

- up
- display containing a liv e video feed which can be used to locate the UAS wh il e it maintains it's position in hover mode. The sUAS has demonstrated it's ability to maintain it's position by GPS coordinates in hover mode in "

- '2Skph wind gusts at rv25 feet representing an extreme e nvironmental condition be yond the range of condi tions within the scope for sUAS operation. All of QCRD 's sUASs utilize LiPo (lithium polyme r) battery based power sources, decreasing safety risks from more easily combustible, fuel based, power sources. Flight times generally last between eight (8) to ten (1 0) minutes allowing the staff to work with small flight areas per phase. The maximum flight time without payload is 15 minut es, however practical safe operation limits this to 10 to give amp le time to control the sUAS to a safe landin g zone. QCRD further restricts flight time by not operating it s sUASs with less than twenty five percent battery capacity

. Further safety management sy stems in place include a GPS mode that allows QCRD sUASs to hover in place i f communication with the PIC is lost and optionally follow a set of way

points at a set speed and height to a 'home base' predesignated safe l anding
zone. In the event of UN

- forseen motor(s) failure, the sy stem will enter into a controlled descent while all owing full use of all UAS flight controls by the PIC. All commands sent via remote controller received during a controlled descent are translated to an 'as meant' paradigm meaning the flight control package will use it's realtime 3 dimensional position and compensate rotors control the sUAS regardless of spin velocity

. This assures that if one sy stem is compensate d a safe and successful landing can still occur.
I V. Reasons W hy an Exempt i on to QCRD Wi ll Not Adversely Affect Safety Standards QCRD 's contends that operation of it's sUASs will not "create a hazard to users of the national airspace sy stem or th e public:' as stated in 112 P.L. 95 §333 (b). Given the diminutive size and weight of QCRD 's sUASs, combined with their operation in cordoned off and well

- controlled areas, QCRD 's sUASs falls within Co ngr ess's contemplated safety zone. QCRD sUASs have an established safety record bolstered by m ulti

- point preflight checkli st, awareness of their surroundi ngs and intim ate knowledge of the behavior of the sUAS platform in many weather conditions. TI1is safety record and impl em ented operational pra ctices demonstrate an awareness of public safety

. QCRD operations routinely provide a level of safety at least equal to existing rules, and in nearly every instance, exceeds existing rules. QCRD has worked very close l y with the regional vendors and support for this unit to cr eate a tightly integrated and highly

tolerant platform that has been tested thoroughly by

a vendor with a proven record for safety and solid designs.

. QCRD also continues to work closely with organizatio n to identify and mitigate sUAS platform risk due t o their expertise in several industries closely related to th e aviation and transportation. QCRD does not operate its UASs on or near airportsand generally has only operated its fleet on private grounds with co rdoned off areas or areas under the control of the property owner I client with assistance by

safety offic ials employed by

the business. QCRD determines the areas needed to fulfill the clients ' goals and only operates its UASs in these flight zones and only in compliance with well regarded safety protocols set forth initially by the RC UAS trade and hobby grou ps and recently codified by

relevant FARs.

Re: Exemption Request Pursuant To Section 333 of the FAA Reform A ct of20 12 QCRD standardized on the foll owing practices to ensure safe operation of it's UASs:
• Work wi th on
- site personnel to plan the flight goa l s, • Work with on
- site personnel to restrict access to non

- esse ntial persons, • Operation by unaided VLOS operation only ,

• Operation in phases 10 minutes in length, Operation to minimal 25% battery power, Operation of d ev i ce to GPS aided readout to 30 0ft at maximum, Num e rous pre
programmed fail

- safes that ensure specific b e havior per i ss u e, Three m a in roles s upplemented by on
- s it e safety p e rsonn e l , E mpl oy contro ll ed life cycle management of compon ent s to guard against mu ltiple failures,
• • • • • • • Pr eform a site check day(s) before flight t o identify pot enti al issues, Subscribe to relevant local
weather and safety

a l erts, Expertly choose data collection in strum ents and accessories to minimize flight requirements or expe rtise, QCRD has experi ence in s imilar fields and has a d apted this experience in it's use of UASs to increase safety

. In co mbination to th e ever expanding knowledge r eposito ri es from hobbyist s and experts alike, QCRD i s constantly evo lving it 's practice s when th e r e is a clear benefit to ope ration s or increas ed safety e l em ent. **A. Summary** Pursuant t o 14 C.F. R. Part 11 , the following summary i s provid e d for publication in the Federal Register, sho uld it b e d etermin ed that publication is needed: QCRD {applicant) see k s an exemption from the fo llowin g rul es : 1 4 C.P.R. §2 1, s ubpart H; 1 4 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 9 1.1 03{b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 9 1.4 09 (a) (2); 91.409 (a) {2) and 91.417 (a) & (b) to operate commercially a small unmanned ve hicle (11kg or less) in elevated photographic and r e mo te sensing ope rati ons. Approval of exemptions allow in g commercial operation s of sUASs in the the media indu stry will e nhan ce safety

by reducing risk associate d with conventional aircraft ope rations and othe r means of elevated r e m ote sensing involving persons. The public benefit se rved by approval of this petition i s increased aware n ess o f characteri stics of difficult imaging targets. A sUAS
we i ghing fewer than 1lkg and powered by sealed batteries eliminates virtually all associate d risk inherent in operating convention al aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would be able t o collect needed d at a. The operation of sma ll UASs, we ighting less than 55lbs., co ndu cted in the stri c t conditions outlined above, will provide an equival e nt l e vel of safety supporting the grant of the exemptions requested herein, including exempting the app li cant from the requirem ents of Part21 and a llowing c omm erc ial operations.

33 SEA AVE, QUIN CY, MA 02169

- 3135 MlNDI@MSAERlAL

. COM + 1

- (8 57)

- 204

- 24 48

PIC VLOS Best, Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of2012 As identified and described herein, Kevin Haley , and his company QCRD .LLC, is an experienced, recognized media services p r ofessional in the various photographic industries. Mr. Hale y and his companies have been producing and delivering media and tec hnical solutions for the media service in du stry for ten (4) years with a spotl ess safety record. The FAA has b een given the authori ty t o i ss u e the exemption to QCRD purs u ant to the Federa l Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek your consideration and approval of this petition.
e ncl: Supplement A: Phy sica l characteristics of UAS encl: Supplement B: Flight Operation and Procedures Manual (FOPM) related to operation encl: Supplement C: Flight maps in QCRD regional base

**VI.** Supplement B : Summary Sections of Flight Operations and Procedure Manual (FOPM) • All regular and i rregular ope rations are noted w i th ti mestamps, relevant UAS metri cs and
co rrective action procedures (CAP) that are performed.

- Note: All irregu l ar behavior have root cause analy sis performed before UAS operation is resumed. **Emergency Pr** **oce du**  **r es**  • Loss of Remote Signal

- The flight package features an optional enhanced fail

- safe which returns the UAS to the h om e base way

po i nt via the same path taken to point of lost signal.

- The UAS will then prefo rm a hove r over this way point and then a co ntro ll ed landing. • Loss of GPS signal

- The sy stem will operate in GPS assisted mode with three (3) satell i tes.

- At l oss of three (3) GPS satellites, manual mode can be activated or the flight package can be programmed to preform a controlled landing to the home base way point.

- Ground based height ranging is prefo rme d by a separate sy stem and so l oss of GPS w i ll not impact controlled landing in a safe manner. • Loss of Engine Power

- In the event of one (1) (or to two oppositely positioned) rotor or motor failure the sy stem will enter into controlled spin where all controls ar e trans l ated based on current
o rientation and will behave as normal operation to the PIC to ensure a safe l anding,

- In the event of multiple rotor or motor failures the flight package can be configured to preform a safe l andi ng or attempt operati on to home base way point.

- Note : Behavior of the landing location is highly dependent on the position and number of rotors/motors that are affected.
• Loss of Ground Control Software

- This w ill not affect operation of the flight. The unit will be piloted to a safe l anding area and then l anded so that examination of the link can be made.http://download.dji

- innovations.com/downloads/nazam

- v2/en/NAZA

M_Quick_Start_ Guide_v1.26_en.pdf

http://www.steadidrone.com/support/check.jpg