August 25, 2015 U. S. Department ofTransportation Docket Management System West Building Ground Floor, Room w12-140 1200 NewJersey Avenue, SE Washington DC 20590


### RE: Exemption Request Section 333 ofthe FAA Reform Act
Dear Sir or Madam: We respectfully request exemption under Section 333 ofthe FAA Reform ACT and Part 11 ofthe Federal Aviation Regulations. Petitioner: Mr. Richard Pelupessy- Wave Technical, Inc. {WTI) 13340 Pergola Ave Bakersfield, CA 93314 Telephone: 661-885-4038 Cell: 805-324-1155 Email:rap@wavetechnical.com WTI intendsto incorporatethe use of UAS commerciallyfor avariety of industries which may include, but not be limited to: Oil 

### & Gas, Solar Energy, Nuclear Energy, Powerdistribution,Telecommunication, Agriculture, Farming and Public Safety. UAS Aerial missions may include but not be limited to: Geographical mapping, thermal imaging, inspections and monitoring, aerial surveying, remote sensing projects, aerial filmmaking, construction monitoring, inspection ofcritical infrastructure, gas leak detection, oil leak detection, wildlife and forestry monitoring photography and real estate purposes, search 

### & rescue operations, etc. 

### Specific Section(s) seeking exemption: 14 C.F.R Part 21 14 C.F.R. 45.23{b) 14 C.F.R. 61.113{a) and {b) 14 C.F.R. 91.7{a) 14 C.F.R. 91.9{b){2) 14C.F.R.91.109 14 C.F.R. 91.119 14C.F.R. 91.121 14 C.F.R. 91.151{a) 14 C.F.R. 91.203{a) and {b) 14 C.F.R. 91.215 14C.F.R. 91.104through 91.417



### Petitionfor FAA Section 333 Exemption Page 1

### Extend of relief requested: To permit commercial operation of Unmanned Aircraft Systems (UAS) for operations conducted within and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. Said exemption would permitthe operation of UAS under controlled conditions in limited, predetermined and controlled airspace. Upon granting ofthis proposed exemption request, WTI would conduct commercial operations of UAS meeting orexceeding all operational and safety requirements per Section 333.


### Public Benefit: 1. Oil & Gas process management, inspections and monitoring. The use of UAS in Oil & Gas operations can improve the safety ofworkers, environmental safety, local residents and general public by assessing potential dangerous situations. In some cases, UAS may reduce or eliminate the use of helicopters or small aircraft currently being used for pipeline patrol; 

### 2. Telecommunications project and construction management, inspections and monitoring of critical telecommunications infrastructure. The use of UAS can improve the safety ofworkers, local residents and general public by assessing potential dangerous situations. UAS can be used to provide tower inspections and can reduce falls and injuries related to that type ofoperations. In some cases, UAS may eliminate the use of helicopters orsmall aircraftto perform similar functions; 

### 3. Environmental Review projects. The use of UAS during the process of reviewing projects as required by 

### 24 C.F.R. 

### 50.4, 58.5 and 

### 58.6 would provide a more in-depth Environmental Review ofthe project site as well as surrounding areas. Reliance of helicopters orsmall aircraft may be eliminated; 

### 4. Aerial surveying. The use of UAS in connection with aerial surveying ofsmaller areas may eliminate the use of helicopters oraircraft. This could provide a more cost effective, safer and can be more energy efficient; 

### 5. Agricultural projects. Wildlife and Forestry projects. The use of UAS could assist with surveying agricultural projects as well as wildlife and forestry projects by providing information on environmental impacts due to drought, crop condition, insect assessment, vermin infestation, fire hazards, etc.; 

### 6. Remote Sensing projects. The use of UAS could provide data collection for remote and in accessible areas. This could promote worker safety as well as reduce the reliance on helicopters and aircraft; 

### 7. Aerial filmmaking, photography and real estate purposes. The use of UAS may provide a point of view previously unavailable through other means. They would be more cost effective, efficient and more safely than helicopters and aircraft; and 

### 8. Search and rescue. The use of UAS may provide assistance to local public safety organizations during search and rescue missions. UAS may reach areas unattainable orviewable with helicopters and aircraft. UAS may be implemented quicker as time is ofthe essence during search and rescue operations.

Petitionfor FAA Section 333 Exemption Page 2

### Reasons why the exemption would not adversely affect safety or how the exemption would provide a level of safety at least equal to the existing rule. Proposed operations using UAS provide increased safety enhancement especially when compared with helicopters and aircraftforthe following reasons: 1. The UAS will weigh less than ten (10) pounds; 2. Flights will be operated within the visual line ofsight ofthe pilot; 3. Maximum total flight time for each operational flight will be thirty (30) minutes. Flight times may be less than thirty (30) minutes as the UAS will continuously monitor battery reserve and return to the ground station with at least 20% battery power reserved; 4. Flights will be operated atan altitude of200 feet AGL. Flights will never exceed 400 feet AGL; 5. Minimum crew for each operation will consist ofthe UAS pilot and aVisual Observer; 6. A briefing will be conducted daily by all personnel working with said UAS; 7. All onsite personnel and client employees will be required to execute a waiver. Verbal/written consent will be required ofall persons within 100feet offlight operation; 8. Written and/ororal permission from relative property owners will be obtained priorto operatingthe UAS; 9. All permits, permissions, etc. will be obtained from local government offices as required; 10. The UAS operated will weigh less than 55 pounds including payload (camera, lens, gimbal, etc.)and 11.The UAS will operate at speeds less than 50 knots, hover and simultaneously movevertically and horizontally; 12. The UAS will have the capability to return and land atthe pre-determined location with the Security Perimeter should the UAS lose communication orGPS signal during any operations; 13. The UAS will have the capability to abort aflight in case of unpredicted obstacles oremergencies; 14. Operations will not be conducted over densely populated areas or heavilytraffic highways; and 15. Operations will not be conducted within five (5) NM ofan airportor heliport. 

### WTI will adhere and comply by all regulations including the following: 1. 14 C.F.R. Part 21, Certification Procedures for Products and Parts. Airworthiness Certificates; 2. 14 C.F.R. 45.23 Display ofmarks; general and 45.29 Size of marks; 3. 14 C.F.R. 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations; 4. 14 C.F.R. 91.7 Civil aircraft airworthiness; 5. 14 C.F.R. 91.9 Civil aircraftflight manual, marking and placard requirements; 6. 14C.F.R. 91.109 Flight instruction; Simulated instrumentflight and certain flight tests; 7. 14 C.F.R. 91.119Minimum safe altitudes: general; 

### 8. 14C.F.R. 91.121 Altimeter settings; 9. 14 C.F.R. 91.151 Fuel requirements forflight in VFR conditions; 10. 14 C.F.R. 91.203 Civil aircraft: Certifications required; 11. 14 C.F.R. 91.205 Powered civil aircraftwith standard category U.S. airworthiness certificates: Instrumentand equipment requirements; 12.14C.F.R. 91.215 ATC transponder and altitude reporting equipment and use; 13. 14 C.F.R. 91.401 Applicability; 14. 14 C.F.R. 91.403 General; 15. 14 C.F.R. 91.405 Maintenance required; 16. 14C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding oralteration; 17. 14C.F.R. 91.409 Inspections; Petitionfor FAA Section 333 Exemption Page 318. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipmenttests and inspections; 19. 14 C.F.R. 91.413 ATC transponder tests and inspections; 20. 14 C.F.R. 91.415 Changes to aircraft inspection programs; and 21. 14 C.F.R. 91.417 Maintenance records. Additional Information: WTI is atechnical firm providing engineering technical support and aviation consulting to fortune 500 companies. Richard A. Pelupessy- President/CEO and private pilot since 1987 and has logged hundreds of hours in private single engine aircrafts. Currently consulting as aSolution Engineer and UAS aviation advisorfor a large Energy company. Richard also has several hours offlying experience in UAS platforms. Larry C. Clever- Chief Pilot and UAS Operations Manager. Former military (Air Force) pilot and is aflight instructorcertificated bythe FFA as a Commercial pilot, CFII, with Single and Multiengine, Instrument, ratings and a Gold Seal endorsement. He has accumulated over 10,000 hours oftotal flighttime as an instructorand commercial pilot. In addition, he holds an MBA in InformationTechnology Management. Larry also has several hours offlying experience in UAS platforms. Proposed UAS Platformsfor WTI Flight Operations:
1. Yuneec Q500 4K 2. Yuneec Tornado H920 3. DJI Spread Wings S1000+ 4. 3DRSOLO

Petitionfor FAA Section 333 Exemption Page4UAS Platforms Specifications: Yuneec QSOO 4K

Typhoon Aucraft Dimension

# f2**2~~~~** ...··.· '
. .**~I'** 'ill;;

. . / 330mm / (U.oln) RightTune upto 25 minutes Weightwith Batteryand Payload 60.0 oz (1700g) Weightwithout Batteryand 40.0 oz (11 30g) Payload Battery 5400mAh 35 II.IV LiPo (included) 4lOmm (16.Sin)
210mm (8.llnJ

Charger 3S 11.1v UPo DC Balancing smart Charger withAC Adapter (included) Transmitter 1 0-channel 2.4GHz with 5.8GHz video downlink (included) 3 Right Modes Smart (Follow Me and Watch Me), Angle and Home MaXimum Flying Height Default 122m (400ft) above Ground level (Adjustable via the Typhoon GUI) MaXImumRotation Rate 65'/s MaXimum Roll Angle 35' OperatingTemperature Range -s·ctoso·c Radio Control FrequeiK'( Band 2.4GHz MaX. DescentSpeed 2mrs MaX. FlightSpeed 8m/s



### Petitionfor FAA Section 333 Exemption Page 5Personal Ground Stat1on Dimensions

Type Operating System Number ofChannels Control Transmission Range (Optimum Conditions) Robust Radio Control Modulation Video Unk Frequency Sand VideoTransmission Range (Optimum Conditions) FlightSystems Telemetry oata On Screen Display LED BadditLCD Screen Tactile (Vibrating) and Audible Feedback Built-in UPo SaneryVoltage 1 capacity Screen Resolution cameraSettings 11Srnm (4.Sitl) STlO+ Android""' 10 188mm (7.4in) l42mm (9.Sin)

FCC Compliance: Up to 800m (2624.67 ft) CE Compliance: Up to 400m (1312.34 ft) Warning You Must Follow Local laws and Mamtain Visual line ofSight ofAircraft at All Times Yuneec Protocol 5.8GHz FCC Compliance: Up to 600m (1968.5 ft) CE Compliance: Up to 300m (984.252 ft) warning: You Must Follow local Laws and Maintain Visual line ofSight ofAircraft at All Times Yes Capacitive Multi-touch 5.5" Yes 3.6V/5200mAh 18.72Wh 854 x 480px White balance, light exposure, 150, shutter speed, video resolution, FPS, record video, take pictures



### Petition for FAA Section 333 Exemption Page 6Yuneec Tornado H920 

# vunc.c.C Ei..EC:Tii;IC**A\'l.t'l.T;O~**

AightTime Dimension Diagonal LengthWithout Rotor Blades Propeller/Main Rotor Diameter Weightwith GB603, GH4 cameraand Banery Banery Charger
Transmitter 4 Right Modes MaXimum Flying Height(Absolutealtirude) MaXimum Aying Height(Relative altirude) MaXimum Rotation Rate MaXimum Roll Angle Maximum Horizontal Speed Radio Control Frequency Band OperatingTemperawre Range



### Petitionfor FAA Section 333 Exemption Page 7

### DJI Spread Wings 51000+

Frame

Motor

ESC

Foldable Propeller (1552/1552R) FrameAmll""G'h

CenterFrameWeight!'MIIll..andingGear-ngBa!se. servos>

ICV



# -- WEighllwilh CoolingFan!



### Petitionfor FAA Section 333 Exemption !OC.Srrm

3l5g

5!)(M'

35g



### Page 8Flight Parameters !I
To!alWeigh!:

HoverPt)'M"fConsumption
HoverTime

Gain Value Setnngs

For Worol<onJ;;M FlightC011!Jullt'f



### Petition for FAA Section 333 Exemption Page 93DRSOLO

Specs: Cameras: Compatiblewith GoPro® HER03, 3+ and 4; optimized for HERQ3.,. and 4 Streamingvideo quality: 720p Righttime: 25 minutes; 20 minuteswith payload" Range: .5 miles- (.8 km) Maxspeed: 55 mph (89 km/h) Maxascent speed: 10 m/s in stabilize mode; 5 m/sin "ffy'' mode Max descentspeed: ditto Max payload: 420 g Max altitude: 400ftper FAA regulation, user adjustable {122m) Motors: 880 kV Propellers: 10"diameter4.5"pitch self-tightening (24 em diameter 144em pitch); glass-reinforced nylon Autopilot: Pixhawk2 Software: APM:Copter Communication: 3DR Link secureWiFi network Frequency: 2.4GHz Weight: 3.3lbs. (1.5 kg) J3.9lbs. (1.8 kg) with GoPro®and Solo Gimbal Dimensions: 10in. taU (25 ern), 18 in. (46 em) motor-to-motor Right batte<y: Lithium polymer 5200 mAh 14.8Vdc Battery chargetime: -1.5 hours Controllerbatte<y: 2600 mAh 7.2 Vdc rechargeable lithium ion App requirements: .OS 8.0 or later I Android 4.3 or later *Flighttimevaries with payload, wind conditions, elevation, temperature, humidity, flying style and pilot skiD. Listed flighttime appliestoelevations lessthan 2,000ft above sea level. **Depending on environmental conditions; controller is expandable, aUowing us orthird partiestoamp up the range in the future.
Solo Sman Battery: Rechargeable lithium polymer (U-Po) 5200mAh 14.8Vdc Weight: 1 lb (.5 kg)
SoloGimbal: Three-axis**stab~ization** Fullycompatiblewith 3DR Solo andGoPro HER03
... and HER04; camera charging and stabilization only with HEROS HDMIvideo output Wireless software upgradethrough Solo Controllable range:

### o• to

### -oo· pitch 

### Petition for FAA Section 333 Exemption Page 10I respectfully submit this Petition for FAA Section 333 exemption. Please feel free to contact d should you have any additional questions orcomments. Sincerely,

Mr. Richard Pelupessy Wave Technical, Inc. 13340 Pergola Ave Bakersfield, CA 93314 Telephone: 661-885-4038 Cell: 805-324-1155 Email:rap@wavetechnical.com

Petition for FAA Section 333 Exemption Page 11