Original				12/16/2015 Page 1 December 16 , 2015 U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 Re: **Exemption Petition under**  **Section 333 of the FAA Modernization & Reform**  **Ac t,**  **and Title 14 Part 11 of the Code of Federal Regulations (CFR)** 14 CFR 61.113, 14 CFR 91. 7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.40 5, 91.407, 91.409, 91.417) Dear Sir or Madam, Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, FlyTek Systems, Inc. files this petition to commercially operate a variety of a irframe s (both fixed wing and multi
- rotor configurations) heretofore referred to as Unmanned Aerial Vehicle (s) or Unmanned Aircraft System (UAS). The requested exemption would support an application for a commercial Certifica te of Authorization (COA) to u tilize the various UAS airframes to offer Aerial Data Collection and Surveying services for all appropriate commercial industries

. A few examples of such industries include, but not limited to, real estate properties, construction site surveys , mapping , 3D modelin g, Oil & Gas industry, structure inspections, Search and Rescue Organizations, agriculture and other potential industries that need aerial data collection. The UAV consists of a lightweight (all under 17 l b s ) battery operated , fixed wing unmanned aircraft, onboard camera and assoc iated communications equipment. All specifications of each airframe is listed on page s 11 and 12 of this document. The various UASs has previously been demonstrated to have successfully met the safety and operational requirements resulting in previous grants of s ection 333 exemption requests by other commercial UAS operators. The P resident of FlyTek Systems, Inc. Mr. Chad Frazer, the designated UAV Flight O perations Lead , has extensive military training (over 2.5 years with 700+ UAV launches/recoveries ) with other UAV platforms and has conducted safe non commercial flight operations with multiple UAV platforms in the NAS pursuant to AC 91
- 57 and its variants

. The various UAVs carry an onboard camera system that allows it to perform a erial data collection , and surveying

. By approving the exemption, FlyTek Systems, Inc. UAS operations will create benefits to both the economy and the environment which are ultimately in the public interest.Original				12/16/2015 Page 2 The aircraft will be operated by a n FAA licensed Pilot in Command for as long as an FAA Airman certificate is required by regulation , and a Visual Observer for as long as required by FAA regulations in accordance with the limitations set forth in the grant

. I n addition the following appli cable restrictions will be followed :

- All operations will occur at no more than 400' above ground level (AGL )

- The aircraft will be operated with the permission of the property owner

- Wh en necessary, applicable permits will be acquired from local authorities

- Operations will be limited to daytime with good visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC at all time s

- Wh ile the aircraft is airborne, the VO (Visual Operator) will be able to communicate verbally with the PIC

- Wh en necessary and applicable, FlyTek Systems, Inc. will file a NOTAM providing radial/DME, radius, and a date/time group for each operation

- The UA will not be operated from any moving vehicle

- The proposed operations will not be conducted during night time F or certain complex operations, FlyTek Systems, Inc. may assign sensor or software operators to assist the operations. We submit that the combination of:

- UAV’s lig ht weight and historically demonstrated safe operation s

- A fully qualified flight crew

- Restricted operation s under the guidelines established within the grant , that t he FAA can have confidence that FlyTek Systems, Inc. UAS the operation s will have an equivalent or greater level of safety of m anned aircraft performing the same mission. Wea re prepared to modify or amend any part of this request to satisfy the need for a n equivalent level of safety. Additional documents supporting this petition will be submitted following this request. Weloo k forward to working with your office. Please contact us at any time if you require additional information or clarification. Respectfully,
Chad Frazer, President FlyTek Systems, Inc. 606 Brookfield Dr. Garland, TX 75040 Tel : ( 980) 333
-2301 Email: chad@flyteksys .comOriginal				12/16/2015 Page 3 

## TA**BLE OF CONTENTS**
NAME, ADDRESS CONTACT INFORMATION OF PETITIONER .....................
. . .... ..Page 4 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH FLYTEK SYSTEMS, I NC. SEEKS EXEMPTION..........................................................................................
. . .... ...................... Page 4 THE EXTENT OF RELIEF FLYTEK SYSTEMS, INC. SEEKS AND THE REASONS FLYTEK SYSTEMS, INC. SEEKS THE RELIEF
... ..... ............................. .... . ...... .... Pages 4 to 6 THE REASONS WHY GRANTING FLYTEK SYSTEMS, INC. S REQUEST WOULD BE INTHE PUBLIC INTEREST.
......................... ....................... .......... ................................... Page 7 THE REASONS WHY GRANTING FLYTEK SYSTEMS, INC. THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY .........
................. .............................. .................... Page 8 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........
. .. . .. .. Page 9 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT FLYTEK SYSTEMS, I NC. REQUEST.................
............... ........ .... ... .... Page 10 AIRFRAME PERFORMANCE CHART ..................................................................P age s 11 & 12 ACRONYMS........................................... ..................................................................Pages 13 & 14Original				12/16/2015 Page 4 **NA ME,**  **AD DRESS A** **ND CONTA CT INFORMA** **TION OF PETITIONER** Chad Frazer FlyTek Systems, Inc. 606 Brookfield Dr. Garland, TX 75040 Tel: (980) 333
-2301 Email: chad@flyteksys.com
**THE SPECIFIC SECTIONS OF 1 4 CFR**  **TO BE RELIEVED FROM** 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417)
**THE EXTENT OF RELIEF**  **FLYTEK SYSTEMS, INC. SEEKS A** **ND THE REA SONS**  **FLYTEK SYSTEMS, INC. SEEKS THE RELIEF**  **14 CFR 61.113 Private pilot privileges and limitations:**  Part 61.113 provides 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) Flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire
. Since the aircraft cannot carry passengers or property, we request to be relieved from this regulation if our pilots at minimum, (1) hold at least a current private pilot certificate and, (2) hold a current third class medical certificate. By meeting conditions (1) and (2), we believe that equivalent level of safety can be achieved by complying with 61.113 Subparagraph (b) even though the intent of this application is to conduct a business.Original				12/16/2015 Page 5 **14 CFR 91.7 Civil**  **Ai rcraft A** **irw orthiness.**  14CFR 9 1.7 (a) states ,

“No person may operate a civil aircraft unless it is in an airworthy condition
. ” T his rule prohibits the operation of an aircraft without an airworthiness certificate. Since there is no such existing certificate that is applicable for any of the airframes sought within this grant to properly comply with the FARs, we request that FlyTek Systems, Inc. to be relieved from this regulation. To provide equivalent level of safety, we will ensure that the UAV is in airworthy condition prior to every flight by following necessary safety procedures and check lists

. **14 CFR 91.119 Minimum safe altitudes: Genera**  **l** This regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement. To provide an equivalent level of safety we will only fly over private property with the permission of the land owner. The land owner will be briefed of the expected route of flight and the associated risks to persons and property on the ground. W e maintain that due to the small size of the UAVs , the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in granting the exemption. **14 CFR 9 1.**  **121 A ltimeter Settings**  Th is regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 nautical miles of the aircraft. The UAVs aircraft will fly below 400 feet AGL and will not need to maintain hemispherical cruising altitudes in order to de
-conflict with other aircraft. To provide an equivalent level of safety, the PIC will check and confirm the UAV’s GPS and the barometric instrument's indicated altitude read out before each fligh t.

**14 CFR 91.1 51 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. We believe the intention of this rule is to provide a reserve of energy as a safety buffer for go
-arounds and other delays to landing.Original				12/16/2015 Page 6 The UAVs are battery operated and the maximum duration of flight with full payload, from a single battery charge is a pproximately 30 to 120 minutes dependi ng on the airframe selected (see full spec sheet at the end of this document for all airframe data)

. Webelieve that a n equivalent level of safety can be achieved by limiting our flight time to 90% of rated flight minutes with a reserved energy of 10% of rated flight minutes on the battery.Original				12/16/2015 Page 7 **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 part 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. It is our intention that the PIC, Visual Observer (VO ) or authorized personnel who perform s maintenance an d inspection of the aircraft "be authorized to approve the aircraft for return to service." F lyTek Systems, Inc. requests that exemptions to the stated regu lations under conditions below: (1) FlyTek Systems, Inc. will follow UAV’s manufacturer maintenance instructions , techniques and procedures

. (2) FlyTek Systems, Inc. will designate, train, and document the personnel who will be authorized to perform Inspection, Maintenance and Alterations

. Such designated personnel may include PIC, VO or other equivalent trained persons

. (3) To ensure equivalent level of safety, PIC will inspect the UA before each flight looking for any structural or mechanical malfunctions

. Due to the small size, light weight and simplicity of the UAV , we believe that the equivalent safety will be achieved by permitting any PIC , VO o r equivalent trained personnel to perform maintenance , inspection and alterations of the aircraft and " be authorized to approve the aircraft for return to service. "Original				12/16/2015 Page 8 **THE REASONS WHY GRA NT**  **ING FLYTEK SYSTEMS, INC.'S**  **REQUEST WOULD BE IN THE PUBLIC INTEREST**  **:** Webelieve that gran ting our exemption request from: 14 CFR Part 21.191 14 CFR Part 45.23, 45.29 14 CFR 61.113 , 61.133 14 CFR 91.9, 91.119 , 91.121 , 91.151 14 CFR 91 Subpart E (91 .405, 91.407, 91.409, 91.417) i s in the public’s interest and will ben efit the public as a whole for the following reasons. 1
- The UAV is battery operated and free from the harmful emissions associated with the manned aircraft that are currently used for aerial photography and videography. As recently proven by several grants of section 333 petitions, UASs offer equivalent level of safety while reducing environmental impacts, which is in the public interest. 2
- FlyTek Systems, Inc. UAS operation s will contribute to a **po sitive**  **aggregate e**  **c onomic**  **i mpact**  resulting in **creation of jobs** both direct and indirectly. Economic Research estimates that the UAS market will grow from $6 billion to $94 billion over the next decade resulting in a new workforce development

. 3
- Because FlyTek Systems, Inc. operations will create **new jobs**  such as pilots, flight operation staff, and administrative supporting staff, it will directly cause **positive economic impact**  , hence granting FlyTek Systems, Inc. petition will benefit the public as a whole. 4
- **Congress has a lready proclaimed**  that it is in the public’s interest to integrate Commercially flown UAS(s) into the national airspace system, hence the passing of the FAA Modernization and Reform Act of 2012. Granting FlyTek Systems, Inc. petition furthers the public’s interest as a demonstrated progression of integrating Unmanned Aircraft Systems into National Air Space, thus it will benefit the public as a whole. 5
- As a unique community service, FlyTek Systems, Inc. will offer, free of charge in most cases , various Search and Rescue flights designed to fi nd missing persons, homicide victims as well as disaster relief intelligence gathering. T his would result in an enormous public benefit.Original				12/16/2015 Page 9 **THE REA SONS WHY GRA** **NTING FLYTEK SYSTEMS, INC.**  **THE EXEMPTION WOULD NOT A** **DVERSELY A FFECT S**  **AF ETY**  **:** FlyTek Systems, Inc. believes t hat the grant of exemption from: 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), will not adversely affect safety by a combination of the reasons listed below. (a) Wehave stated in the above section **“ THE EXTENT OF RELIEF**  **FLYTEK SYSTEMS, INC.**  **SEEKS AND THE REASONS FLYTEK SYSTEMS, INC.**  **SEEKS THE RELIEF ”** by describing how we intend to mitigate risk and accomplish FAA equivalent and acceptable level of safety for each 14 CFR part. (b) As a result of UAVs unmanned aircraft’s size, weight, speed, operational capability, proximity to airports and populated areas, operation within visual line of sight combined with the implement ing of FAA required safety procedures , we believe that granting FlyTek Systems, Inc. exemption request will not adversely affect safety. (c) The various UAV System s selected has been demonstrated to satisfy necessary safety risk mitigation by FAA thus resulting in multiple grants of section 333 petitions of similar fixed wing UAS

. Because of the combination of UAV’s proven success and the conditions and limitations of our operations, we believe granting FlyTek Systems, Inc. request will not adversely safety.Original				12/16/2015 Page 10 **SUMMA RY THA** **T CAN BE PUBLISHED IN THE FEDERA L REGISTER**  **:** Department of Transportation Federal Aviation Administration Petitioner: FlyTek Systems, Inc. Petition of exemption from section s of: 14 CFR 61.113, 14 CFR 91.7, 91.119, 91.121, 91.151 14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) Description of relief sought; FlyTek Systems, Inc. se eks an exemption for commercial operati on of the following UAS

. The UAVs listed may have an onboard camera system capable of acquiring high resolution data.

Proposed operations will offer aerial data collection and surveying services for appropriate commercial industries. Aircraft Name Manufacturer Albatross Applied Aeronautics Buffalo FX79 Sky

Wa lker Air Titan Finwing Penguin V2 Finwing Phantom FX61 Zeta Anaconda RMRC Skua X
- UAV SkyObserver X
- UAV SkyHunter Origin X8 Sky

Wa lker TechPod Wa ne Garris Phantom 2 DJI Phantom 3 DJI Inspire 1 DJIOriginal				12/16/2015 Page 11 **AN Y**  **AD DITIONA** **L INFORMA** **TION, VIEWS,**  **OR AR** **GUMENTS AV** **AI LA** **BLE TO**  **SUPPORT FLYTEK SYSTEMS, INC**  **. REQUEST**  

## Unmanned **Ai rcraft System**  **s Section General Features**  **of A ll A** **irframes Proposed:**

 ST Micro L3GD20 3
-axis 16
- bit gyroscope
 ST Micro LSM303D 3
-axis 14
- bit accelerometer / magnetometer
 Invensense MPU 6000 3
-axis accelerometer/gyroscope
 MEAS MS5611 barometer
 20 to 120 min ute s of Flight Time
 Auto Return
-to - Home & Landing
 Advanced Power Management
 Integrated backup system for in
-flight recovery and manual override with dedicated processor and stand
-alone power supply
 Backup system integrates mixing, providing consistent autopilot and manual override mixing modes
 Redundant power supply inputs and automatic failover
 External safety button for easy motor activation and deactivation
 Multicolor LED indicator to visually display Autopilot Status
 High
- power, multi
-tone piezo audio indicator
 microSD card for long
-time high
- rate logging
 Easy Battery Replacement
 CAN
- Bus Expansion Module
 Control Link radio operating frequency 2.4 GHz ISMOriginal				12/16/2015 Page 12 

### Ai **rcraft Performance Chart**  Aircraft Name Manufacturer Empty We ight Max Take

Off W eight Max

Flight Speed Wi ng Span Flight Time Albatross Applied

Aeronautics 14lbs 17.6lbs 60mph 8ft 120min Buffalo FX79 Sky

Wa lker 6lbs 9lbs 60mph 79in 90min Air Titan Finwing 8lbs 15lbs 60mph 8ft 45min Penguin V2 Finwing 3lbs 5lbs 45mph 68in 60min Phantom FX61 Zeta 3.1lbs 4.5lbs 45mph 61in 60min Anaconda RMRC 5lbs 8lbs 60mph 7ft 60min Skua X
- UAV 4.2lbs 8lbs 50mph 7ft 120min SkyObserve r X
- UAV 4.5lbs 6.5lbs 45mph 79in 60min SkyHunter Origin 6lbs 9lbs 55mph 71in 60min X8 Sky

Wa lker 4.5lbs 8lbs 60mph 84in 90min TechPod Wa ne Garris 2.75 5lbs 64mph 102in 120min Phantom 2 DJI 4lbs 6lbs 30mph Multi
- Rotor 20min Phantom 3 DJI 4lbs 6lbs 30mph Multi
- Rotor 20min Inspire 1 DJI 4lbs 6lbs 30mph Multi
- Rotor 20minOriginal				12/16/2015 Page 13 

### N **o Privacy**

**Issues** FlyTek Systems, Inc. proposed operations will create no privacy issues because the UAV will be operating in the areas within the boundaries of the propert ies with the land owner’s permission. Wh en necessary, FlyTek Systems, Inc. will also obtain any permits or authorizations from local authorities. **AC RONYMS**  AGL Above Ground Level ALoS Acceptable Level of Safety AMOC Alternative Method of Compliance ASI Aviation Safety Inspector ATC Air Traffic Control ATCAA Air Traffic Control Assigned Airspace ATS Air Traffic Service AVS Aviation Safety CFR Code of Federal Regulations COA Certificate of W aiver or Authorization CRM Crew Resource Management CS Control Station CRS Certified Repair Station DCP Divert/Contingency Point DHS Department of Homeland Security DME Distance Measuring Equipment DOD Department of Defense DSA Detect, Sense, and Avoid System FAA Federal Aviation Administration FCC Federal Communications Commission FA Rs F ederal Aviation Regulations FIR Flight Information Region FL Flight Level FSIMS Flight Standards Information Management System FTP Flight Termination Point FTS Flight Termination System Crosstimbers FlyTek Systems, Inc. , LLC G Hz Gigahertz GCS G round Control Station MHz Megahertz MTOW M aximum Takeoff W eight NAS National Airspace System NM Nautical MileOriginal				12/16/2015 Page 14 N O TA M N otice To Airman OPA Optionally Piloted Aircraft PIC Pilot in Command UAVs UAVs Unmanned Aircraft System UAVs UAVs Unmanned Aircraft R&D Research and Development RF Radio Frequency RM Risk Management RNAV Area Navigation RTB Return to Base RVSM Reduced Vertical Separation Minimum TAS Traffic Advisory Systems TC Type Certificate UA Unmanned Aircraft UAS Unmanned Aircraft System (s) UAV Unmanned Aerial Vehicle VFR Visual Flight Rules VMC Visual Meteorological Conditions VO Visual Observer