US Department ofTransportation Exemption Request Pursuantto Section333 of the FAA

Reform Act and Part 11 ofthe Federal Aviation

January 8, 2016

William Louis Kennedy QC Drone Services 

### 3715West44th St. Davenport, lA 52806 bill@qc_drones.net

U.S.DepartmentofTransportation Docket Management System 1200 NewJerseyAve., SE Washington DC 20590

Re: Exemption Request Pursuantto Section 333 ofthe FAA Reform Act and Part 11 ofthe Federal Aviation Regulations from: 14CFR 21 subpart H; 14CFR 45.23(b); 14CFR 61.113(a) and (b); 14CFR 91.7(a); 14CFR91.9(b)(2); 14CFR 91.103; 14CFR 91.109; 14CFR 91.119(c); 14CFR 91.121; 14CFR 91.151(a); 14CFR 91.203(a) and (b); 14CFR 91.405 (a); 14CFR 91.407 (a) (1) 14CFR 91.409 (a)(1) and (2); 14CFR 91.417(a) and (b)

The exemption is in the public interest. Pursuantto the authority contained in49 U.S.C. 106(f), 40113, and 44701.

Dear Siror Madam:

Pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (the "Reform Act") and 14CFR Part 11 of Unmanned Aircraft Systems (UAS}, William louis Kennedy hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allowcommercial operation of Designated UAS, provided such operations are conducted within and underthe conditions out.IJped herein or as may be established bythe FAA as required by Section 333.**~\**<:

Thank you in advance for your consideration.Commercial operation ofan UAS, as described herein, which are equipped with camera(s) and sensors, would provide professional services in the following
areas:

1. Real Estate 2. Education and Special Events 3. Videography I Photography 4. Search and Rescue 5. Publicand Private Events 6. Agricultural Inspections 7. Construction Site Monitoringand Documentation 8. Insurance Claims Documentation 9. Residential and Commercial Inspections

As described fully below, the requested exemption would permitthe operation of designated UAS as setforth in this document undercontrolled conditions in the NASthat would be a) limited b) controlled c) predetermined and d) safe. Approval ofthis exemption would increase public awareness of UAS operations and enhance safetyto aid in fulfilling the SecretaryofTransportation's (the FAA Administrator's) responsibilities to"

.... establish requirements forthe safe operation ofsuch aircraft systems in the national airspace system."

The name and address ofthe applicant is

William Louis Kennedy QC Drone Services 3715 West44th St. Davenport, lA52806 bill@qcdrones.net

From whichthe exemption is requested: 14CFR Part 21 subpart H 14CFR 45.23 (b) 14CFR 61.113 (a) & (b) 14CFR 91.7 (a) 14CFR 91.9 (b) (2) 14CFR 91.103 14CFR 91.109 14CFR 91.119 (c) 14CFR 91.121 14CFR 91.151 (a) 14CFR 91.203 (a) 14CFR 91.405 (a) 14CFR 91.407 (a)14CFR 91.409 (a) 14CFR 91.417 (a)

As in Grants of Exemption Nos. 11062to Astraeus Aerial (see Docket No. FAA-2014-0352), 11109to Clayco, Inc. (see Docket No. FAA-2014-0507), 11112to VDOS Global, LLC (see Docket No. FAA-2014-0382), 11213to Aeryon Labs, Inc. (see Docket No. FAA-2014-0642), and 12645to Allied Drones (see Docket No. FAA-2014-0804), There is enhanced safety achieved using an unmanned aircraft (UA) with the specifications described bythe petitioner and carrying no passengers orcrew, rather than a manned aircraft ofsignificantly greater proportions, carrying crew in addition to flammable fuel, givesthe FAA good causeto find thatthe UAS operation enabled bythis exemption is in the public interest.

William Louis Kennedy Will operate one or more ofthe Following model UAS

DJI F550 with Naza V2, Tarot 810 Sportwith Naza V2, Arris M680 with OJI WooKing
Safety requirements. The approval ofthis application presents no national security issues. Regarding the level ofsafety surrounding the proposed operations and the public benefit, reduction in environmental impacts, including but not limited to reduced emissions and noise, the grant ofthe requested exemption is in the public interest. Accordingly, the applicant graciously requests thatthe FAA grantthe requested exemption.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level ofsafety because operations will further enhancethe safetyofthe persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agreesto adhereto when conducting commercial operations underthe FAA issued exemption as set forth in the Flight Operations Manual (FOM) include:

1.The UAS will weigh significantly lessthan 551bs.

2. The UAS, depending on the model in operation, will have a maximumoperating speed of no more than 50mph.

3. Flights will be operated within line of sight ofthe Pilot in Command (PIC) and/orVisual Observer (VO).

4. Maximum flight time for each operational flight will be depending on the UAS model in operation, but will not exceed 30 minutes. Flights will be terminated at 25o/o battery power reserve or 30 minutes offlight time whicheveroccurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL) and not more than 200 feet above an elevated platform from which filming is planned.

6. Minimum crewfor each operation will consist ofthe UAS Pilot and at least one Visual Observer (VO), and may include athird, but separate, Camera Operator (CO).

7. The UAS pilot will be adesignated Pilot in Command (PIC). The PIC will have logged a minimum of20 hours on the designated UAS.

8. Asafety briefing will be performed priorto each day's flights consisting of all the days' Production activities.

9. All flight activities will be logged.

10. All flights will occur underVisual Flight Rules Meteorological Conditions (VMC) only.

11

.The flights will occur in Class Gairspace no closerthan a mile radius ofthe geographic center/Airport Reference Point (ARP) of atower controlled or uncontrolled airport.

12. Flights will not be closerthan a 5 mile radius ofthe geographic center/Airport.

13. The operator will do a pre check of aircraft priorto each flight. And log each flight.

14. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure that onlyconsenting persons will be allowed within1 00 feet ofthe flight operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety determination, as U.S. Department of Transportation required underthe FOM. With the advanced permission ofthe FSDO, operations at closer range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive up to date information forthe particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice and/or radio at all times.

17. The PIC will abide by all rules

18. Ifthe UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capabilityto return to a predetermined location within adesignated location and land autonomously.

19. The UAS will have the capabilityto abort aflight in case of emergencies with
an automated "Return Home and Land" function.

20. The UAS will have the capabilityto abort aflight in case of unpredicted obstacles, weather, or emergencies such as low battery.

21. Any incident, accident, orflight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COA must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraftto be utilized bythe Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level ofsafety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section333 ofthe Reform Act both authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size,weight, speed, operational capability, and proximityto airports and populated
areas ofthe particular UAS. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate in the restricted environment and underthe conditions proposed will be at least as safe,
or safer, than aconventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate withoutthe restrictions and conditions proposed. The UAS to be operated hereunder is less than 551bs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials orflammable liquid fuels, and operates exclusively within asecured and designated area. Unlike othercivil aircraft, operations underthis exemption will be tightlycontrolled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. These safety enhancements provide agreaterdegree of safetyto the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstratesthatthere is no credible threat to national security posed bythe UAS, due to its size, speed of operation, location ofoperation, lack of explosive materials or flammable liquid fuels, and inabilityto carry asubstantial external load.

14 C.F.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restrictedor light sport category aircraft or experimental or provisionallycertificated aircraft, the operator must also display on that aircraft
neareach entrance to the cabin, cockpit, orpilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited/' "restricted/' "light sport/' "experimental/' or "provisional/' as applicable.

14 C.F.R. §45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include onlythe Roman capital letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionallycertificated aircraft, the operator must also displayon that aircraft
near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited/ "restricted/' "light sport/'"experimental/' or "provisional! as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe UAS, two inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). US Department ofTransportation February 20, 2015 The equivalent level of safetywill be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." 14 C.F.R. 

### § 61.113 (a) and (b The proposed UAS operations may achieve an equivalent level of safety as achieved by current Regulations because the applicant's UAS do notcarry any pilots or passengers nor property. The risks attendantto the It is believed thatthe operation and limitations set forth in the FOM will equate to the safe operation ofthe UAS.

14 C.F.R. §91.7{a): Civil Aircraft Airworthiness. The regulation requires that no person may operate acivil aircraft unless it is in airworthycondition. As there will be no airworthiness certificate issued forthe aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft for maintenance and use of safetychecklists priorto each flight, an equivalent level of safety will be provided. 14 C.F.R. 

### § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) {2) provides: No person may operate a U.S. registered civil aircraft

... (2) Forwhich an Airplane or Rotorcraft Flight Manual is not required by §21.5 ofthis chapter, unless there is available in the aircraft acurrent approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and configuration has no abilityor place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacityto carry such an item on the aircraft. The equivalent level ofsafety will be maintained by keeping the flight manual atthe ground control point where the pilot flying the UAS will have immediate access to it.

14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot in command to take certain actions before flight to insure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation offlight.

14 C.F.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate acivil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UAS and remotely piloted aircraft, bytheir design do not have fully functional dual controls. Flight control is accomplished through the use ofacontrol boxthat communicates with the aircraft via radio communications. The FAA has approved exemptions forflight training without fully functional dual controls for a numberof aircraft and forflight instruction in experimental aircraft. The equivalent level of safety is provided bythe factthat neither apilot nor passengers will be carried in the aircraft and bythe size and speed ofthe aircraft.

14 C.F.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.119 (d) allows helicoptersto beoperated at less than the minimums prescribed, provided the person operating the helicoptercomplies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the exemption requestsauthorityto operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, the UAS will neveroperate at higherthan 400 AGL with the exception that in circumstances where the UAS is used to surveyor photograph astructure whose height exceeds 400 feet AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre obtained consent. The equivalent level of safety will be achieved given the size, weight, and speed ofthe UAS as well asthe location where it is operated. No flight will be taken withoutthe permission ofthe property owneror local officials. Because ofthe advance notice to the property owner and participants in the filming activity, all affected individuals will be aware ofthe planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far
more than the maximum SSibs. Proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below500 AGL. In addition, the lowaltitude operations ofthe UAS will ensure separation between these UAS operations and the operations of conventional aircraftthat must comply with Section 91.119.

14C.F.R. §91.121 Altimeter Settings. This regulation requires each person operating an aircraftto maintain cruising altitude by referenceto an altimeterthat is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UAS may not have abarometric altimeter, but instead aGPS altitude read out, an U.S. exemption may be needed. An equivalent level ofsafetywill be achieved bythe operator, pursuant to the safetycheck list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to flyto the first pointof intended landing, and, assuming normal cruising speed- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes."The applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. Operating the UAS in atightly controlled area where only people and property
owners orofficial representatives who have signed waivers will be allowed does not engenderthe type of risks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. The applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or25°/oof battery power- whichever happens first. This restriction would be more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person mayoperate acivil aircraft unless it has within itthe following: (1) An appropriate and current airworthiness certificate

.... (b) No person may operate acivil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section or aspecial flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legibleto passengers or crew. The UAS fully loaded weighs well underthe'proposed 551b limit and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents orto displaythem on the UAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them, to the extentthey are applicable to the UAS.

14C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) 

### &(b): Maintenance

\ Inspections. These regulations require that an aircraft operatoror owner "shall have that aircraft inspected as prescribed in subpart Eofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part43 ofthis chapter

...," and others shall inspector maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 applyonlyto aircraft with an airworthiness certificate, these sections will not applyto the applicant. Maintenance will be accomplished bythe operator pursuant to the flight manual and operating handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry asmall payload and operate only in restricted areas for a limited period oftime. If mechanical issues arise the UAS can land immediatelyand will be operating from no higherthan 400 feet AGL. The operator will ensure thatthe UAS is in working order priorto initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person mostfamiliar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User Manual. As provided in the FOM, and a linkon last page, the operator will ensure that the UAS is in working order priorto initiating flight and perform required maintenance needed.Additional Information.

The applicant William Louis Kennedy believes this exemption request and associated safety considerations adequately satisfy criteria provided in Section 333 ofthe Reform Act of2012, providing sufficientjustification forthe granting of commercial operations ofthe applicant's UAS. Ialso feel its in the public's interest on granting the exemption, as we can educate them atthe same time. And all the positive sides ofthe newtechnology and the level ofsafety.

The applicantWilliam Louis Kennedy requests your respective approval ofthis Section 333 exemption petition request.

Thank you for your attention in this matter. Please notifyWilliam Louis Kennedy ofyour actions, and or approvals. Thankyou, for your interest in this request.

Sincerely,

William Louis Kennedy