1 

### U.S. Department of Transportation Federal Aviation Administration Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Regulatory Docket No. _______________



### Exemption Request Under Section 333 of the FAA Reform Act and

Part 11 of the Federal Aviation Regulations

Submitted on August 18 , 2015

Todd B Zavodney President Chateau Services, Inc. 248 Cole Ave. Akron , OH 44301 800

-216

- 3674 Todd@ChateauService .com2 

### TA**BLE OF CONTENTS**  PAGE GLOSSARY OF ABBREVIATIONS..................

...... .............................3 INTRODUCTION AND OVERVIEW.......................

.......... . . ................. 4 CHARACTERISTICS OF THE UAS.................................

. .................. 5 SPECIFICATIONS OF THE UAS.............................................. 6 UAS OPERATOR REQUIREMENTS.................................

. ................ 7 UAS OPERATING PARAMETERS...................................

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

- 9 AP PLICATIONS AND PUBLIC INTEREST.........................

... .. .........10 SUMMARY FOR FEDERAL R EGISTER...............................

.... .........8 CONCLUSIONS..........................................................................

. .......9 APPENDIX A: REGULATIONS REQUIRING EXEMPTION

...... . 11

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**GLOSSA RY OF**  **ABBREVIA TIONS**  AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization 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 MPH Miles Per Hour NAS National Airspace System NOTAM Notice to Airman PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 SVFR Special Visual Flight Rules UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Site VMC Visual Meteorological C onditions VO Visual Observer INTRODUCTION AND OVERVIEW4

Dear Madam/Sir, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Chateau Services, Inc. (“Chateau”), seeks an exemption from the Federal Aviation Regulations listed below:

 14 C.F.R. 21, subpart H
 14 C.F.R. 61.3
 14 C.F.R. 61.113(a)&(b)
 14 C.F.R. 61.133(a)
 14 C.F.R. 91.9(b)(2)
 14 C.F.R. 91.103(b)
 14 C.F.R. 91.105
 14 C.F.R. 91.109(a)
 14 C.F.R. 91.119
 14 C.F.R. 91.121
 14 C.F.R. 91.151(a)
 14 C.F.R. 91.203(a) & (b)
 14 C.F.R. 91.319(a)(1)
 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417)
The requested exemption would authorize Chateau to conduct com mercial operations using the Yunee c Q 500 4K for photography/videography for forensic inspection and loss control applications. These applications would primarily consist of roofing inspections, building façade inspection, industrial smoke stack inspection and site/scene of property loss d ocumentation. In order to ensure at least an equivalent level of safety to currently authorized operations using manned aircraft, all operations will be subject to the strict operating requirements defined in the Chateau U AS Flight Operations Guide. Additionally, this petition for exemption is supported by the information contained in the Yunee c Q500 4K User Manual. The characteristics of the UAS, detailed UAS operator requirements, and UAS operating parameters given below will ensure that all Chateau UAS operations are carried out with an equivalent or higher level of safety than currently authorized unmanned aircraft operations. The details below regarding Chateau’s intended UAS applications provide clear evidence that ap proval of this exemption is in the public interest.5 CHARACTERISTICS OF THE UAS
Technical Specifications for the Yunee c Q500 4K: http://yuneec.com/products/aerialuav/q500_4k/specifications.html
Each UA operated by Chateau for commercial use will be registered in accordance with 14 C.F.R Part 47, and will be marked in accordance with 14 C.F.R. Part 45, , Subpart C, in a size as large as practical for the size of the UA. All UAS operated by Chateau will be maintained in accordance with the manufacture’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components and all pertin ent instructions in the user manuals. Repairs, component changes, and software/firmware updates will be recorded in the UAS’s maintenance log. Maintenance log entries will include the date, UAS ID number, registration number, current UAS flight time, a des cription of work performed, and the name of the individual who completed the work. 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, prior to use in any commercial operations. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. The PIC who conducts the functional test flight must make an entry in the aircraft records. A pre

-flight inspection of the UAS will be completed by the PIC prior to each flight operation as specified in the Chateau UAS Flight Operations Guide . If the inspection reveals a condition that affects the safe operation of the U AS, 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. All Chateau UAS will comply with all applicable manufacturer safety bulletins.6

Additional information on the aircraft specifications, performance limitations, operating procedures : 

## Q500 Typhoon Warning Sheet http://yuneec.com/support/downl oad/manuals/typhoon_q500_warning_sheet_v1. 0.pdf 

## Q500 Typhoon New Flight Mode Features http://yuneec.com/support/download/manuals/typhoon_q500_new_fli ght_mode_f eatures_v1.0.pdf 

## Q500 Typhoon Compass Calibration http://yuneec.com/support/download/manuals/typhoon_q500_compass_calibratio n_v1.0.pdf 

## Q500 Typhoon LED Status Indications http://yuneec.com/support/download/manuals/typhoon_q500_led_status_indicati ons_v1.0.pdf 

## Q500 Typhoon Quick Start Guide v2.1 http://yuneec.com/support/download/manuals/typhoon_q500_quick_start_guide_ v2.1.pdf 

## Q500 Typhoon Instruction Manual v2.1
http://yuneec.com/support/download/manuals/typhoon_q500_instruction_manual _v2.1.pdf 

## Q500 4K Typhoon User Manual v1 http://yuneec.com/support/download/manuals/q500_4k_user_manual.pdf7 UAS OPERATOR REQUIREMENTS

All Chateau UAS operators will hold at least an FAA issued private, recreational, or sport pilot certificate and will have successfully completed Chateau’s UAS Training Curriculum. Completion of the Chateau UAS Training Curriculum will ensure safe operations by not allowing any PIC to operate a UAS unless that PIC has dem onstrated, that he/she is able to safely operate the UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. All operators will either mee t the flight review requirements specified in 14 CFR § 61.56 or will annually complete and log at least 4 hours of ground instruction with a certified flight instructor (CFI) covering regulations and issues pertinent to commercial operation of the UA. Th e individual acting as PIC of a UAS will be identified prior to any flight and will not change once the flight has begun. The PIC is the individual in operational control of the flight operation from beginning to end and is responsible for safe flight of t he UA. All PIC flight hours used to demonstrate qualifications and currency will be logged in a manner consistent with 14 CFR § 61.51(b). In order to act as PIC, all Chateau UAS operators will hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government.8 UAS OPERATING PARAMETERS In order to provide for a level of safety at least equivalent to operations conducted using manned aircraft, all Chateau commercial UAS operations will be conducted in accordance with the following specific operating limitations:

 The UA may not be operated at a speed exceeding 30 knots (34 miles per hour). In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
 All operations shall be conducted in accordance with an ATO

- issued COA.
 All UA operations will occur at or below 4 00 ft AGL or the maximum altitude specified in the COA limitations, unless the purpose of the flight is to inspect a building or structure which is taller than 4 00 ft. If the p urpose of the flight is to inspect a building or structure which is taller than 4 00 ft then the max altitude of the UA will be restricted to 20 ft above the highest point of that building or structure. All altitudes must be reported in feet AGL.
 No UA will be operated within 3 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to Chateau . The letter of agreement with the airport management must be made available to the Administrator or any law enforceme nt official upon request.
 No UA will be operated within class B, C, D or E airspace unless a letter of agreement from the controlling ATC office is obtained or the flight is otherwise permitted by a COA issued to Chateau . The letter of agreement from AT C must be made available to the Administrator or any law enforcement official upon request.
 The UA must be operated within visual 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 ot her than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license.
 All operating documents and a 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 in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations in the grant of exemption take precedence and must be followed. Otherwi se, the PIC must follow the procedures as outlined in the operating documents. Chateau may update or revise its operating documents. However, it is Chateau ’s responsibility to track such revisions and present updated and revised documents to the Administra tor or any law enforcement official upon request. Chateau must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If Chateau determines that any update or revision would affect the basis upon wh ich the FAA granted the exemption, then Chateau must petition for an amendment to the grant of exemption.9

 UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditio ns (VMC). Flights under special visual flight rules (SVFR) are not authorized.
 The UA may not be operated less than 5 00 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
 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 affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has b een performed and the UAS is found to be in a condition for safe flight. All maintenance and alterations must be properly documented in the aircraft records.
 Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight c haracteristics, 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.
 If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location.
 The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
 The PIC is prohibited from beginning a flight unless the UA’s battery level is at 75% or higher. The PIC must begin returning the UA to the designated landing area when the battery level drops below 25%.
 Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the P IC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
 The UA must remain clear and give way to all manned aviation operat ions and activities at all times.
 The UAS may not be operated by the PIC from any moving device or vehicle.
 UA will not be operated directly over nonparticipating persons unless barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. UA will not be operated over any open -air as sembly of people.
 Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's UAS Integration Office (AFS

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

.10

APPLICATIONS AND PUBLIC INTEREST The requested exemption would allow Chateau to operate the Yuneec Q500 4K for the purposes of roofing inspections, building façade inspection, industrial smoke stack inspection and site/scene of property loss documentation . These inspections and investigations are completed on both residenti al and commercial properties and are typically conducted in support of the property insurance industry. Use of UAS for these applications will offer significant advantages related to safety, time, and cost. Most properties throughout the country are insure d, and property owners have an interest in insurance underwriting, coverage, and claims processing; therefore it is clear that grant of this exemption would be in the public interest. Current options for gathering the data which under this exemption would be collected using UA, include use of ladders, lifts, and manned aircraft. Use of ladders and lifts are inherently dangerous and result in numerous injuries each year. Use of manned aircraft is typically not feasible and therefore valuable information rema ins beyond the reach of the in spector . In most cases, use of a UA is quicker and easier than any other alternative and often yields better information. Due to their small size and the fact they carry no combustible or explosive fossil fuel s , UA’s pose a ve ry low risk of damage to persons or structures on the ground. Because these UA are electric powered, they create no harmful emissions and make very little noise. SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER Chateau Services, Inc. requests the gra nt of an exemption to the following specific sections of the Title 14 Code of federal Regulations which would allow it to operate micro UAS for commercial use: 14 CFR 21, subpart H, 14 C.F.R Sections 61.3, 61.113(a)&(b), 61.133(a), 91.9 (b)(2), 91.103(b), 91.105, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407, 91.409, 91.41711

**AP PENDIX A**  **: REGULA TIONS REQUIRING EXEMPTION**  Chateau requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the Yuneec Q500 4K UAS: **14 C.F.R. Part 21, Subpart H: A irw** **orthiness Certificates 14 CFR § 91.203(a)(1)**  Section 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a ). Given the size of the UA, it is very light weight, and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H in order to achieve or exceed current safety levels. Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requireme nt for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS involved. An analysis of these different criteria demonstrates that the UA operated without an airworthiness certificate, under the conditions proposed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an airworthiness certificate. **14 C.F.R. § 61.3: Requirements for certificates, ratings and authorizations 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and**  **Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations** The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft of t he United States, unless that person: (1) Has a pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authorization. However, when the aircraft is operated within a foreign country, a pilot license issued by that country may be used. The regulation provides also that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; (2) The aircraft doe s not carry passengers or property for compensation or hire.12 Given the size, weight, speed, operational limitations, and range of the UAS, Chateau proposes that operators of the UAS should not be required to hold a commercial pilot certification. Instead , operators should be required to: Hold at least an FAA issued private, recreational, or sport pilot certificate. All operators will 11 either meet the flight review requirements specified in 14 CFR § 61.56 or will annually complete and log at least 4 ho urs of ground instruction with a certified flight instructor (CFI) covering regulations and issues pertinent to commercial operation of the UAS. **14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and placard requirements.**  This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. Chateau proposes to provide an equivalent level of safety by maintaining a copy of all documents used by the operator to ensure the safe operation and flight of the UAS as well as documentation of an exemption and COA with the ground control station and accessible to the PIC during flight operations. **14 C.F.R. § 91.103: Preflight action** This regulation requires that each pilot in com mand shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include runway lengths at airports of intended use, and the following takeoff and landing distance information. This regul ation is not applicable due to the fact Chateau UAS operations will not occur at an airfield. To provide an equivalent level of safety, the PIC will complete a preflight inspection as directed by the manufacturer’s manuals and Chateau UAS O perations Guide before any flight. **14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction** The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The equ ivalent level of safety will be achieved through Chateau ’s UAS flight training program and conducting flight training within controlled environments. **14 C.F.R § 91.105: Flight Crew members at Stations**  The regulation states that required crewmembers must be at their stations in the aircraft during specific portions of a flight. This is not applicable since the UA carry no crewmembers. An equivalent level of safety will be maintained by ensuring that the PIC is identified prior to any flight and that the PI C does not change during a flight. The PIC will maintain control of the UAS for the duration of the flight **14 CFR § 91.119: Minimum Safe A ltitudes** 13

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer 12 than 500 feet to any person, vessel, vehicle, or structure. Since the UA will be operating at a maximum of 500 feet AGL, these operations cannot comply wit h this requirement. The equivalent level of safety will be achieved given the size, weight and speed of the UAS. Additionally the UAS will be operated in a defined and relatively small AOI. Moreover, the UA will not be operated over any open

-air assembly of persons or over any person not involved with the operation. The aircraft will be operated at an altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. **14 CFR 91.121**
**– Al**  **timeter settin gs**  This section requires that 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 below 18,000 feet MSL to:
 The current rep orted altimeter setting of a station along the route and within 100 nautical miles of the aircraft;
 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 availa ble station;
 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. To provide an equivalent level of safety, the UAS utilize a GPS system, barometri c pressure sensors, and internal gyroscopes to calculate the altitude. **14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions** The regulation provides that no person may begin a flight in an airplane under day

-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. Given the area of operation for the UAS, Chateau believes that an equivalent level of safety is achieved by requiring at least 75% battery power in order to begin a flight and requiring the UA to return to land when the battery power reaches 25%. **14 C.F.R. § 91.203 (a) & (b): Carry ing Civi**  **l A ircraft Certification and**  **Registration** This regulation provides as follows:
 No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate.
 No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew

. To obtain an equivalent level of safety and meet the in tent of 91.203, Chateau proposes to maintain a copy of all documents used by the operator to ensure the safe operation and flight of the UAS as well as documentation of an exemption14

and COA with the ground control station and these will be 13 available to the Administrator or any law enforcement official upon request. **14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417) -**  **Maintenance, Preventive Maintenance, and A** **lterations** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. Section 91.40 9(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, o r licensed pilots and records of approval of the aircraft for return to service. Chateau proposes that the maintenance, as well as preflight inspections of the UAS will be accomplished by the PIC. All maintenance will be conducted and logged in accordance with the Chateau UAS operations manual and the manufacturer’s specifications. An equivalent level of safety will be achieved because the UAS are small in size, are not complex mechanical devices, and will carry no external payload.