August 25, 2015 

U. S. Department of Transportation 

Docket Management System 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam: 

We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of the 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 intends to incorporate the use of UAS commercially for a variety of industries which may include, 

but not be limited to: Oil & Gas, Solar Energy, Nuclear Energy, Power distribution, 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 of critical 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) 

14 C.F.R.91.109 

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) and {b) 

14 C.F.R. 91.215 

14 C.F.R. 91.104 through 91.417 

Petition for FAA Section 333 Exemption Page 1 
Extend of relief requested: 

To permit commercial operation of Unmanned Aircraft Systems (UAS) for operations conducted within 

and under the conditions outlined herein or as may be established by the FAA as required by Section 

333. 

Said exemption would permit the operation of UAS under controlled conditions in limited, 

predetermined and controlled airspace. Upon granting of this proposed exemption request, WTI would 

conduct commercial operations of UAS meeting or exceeding 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 of workers, 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 of workers, 

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 of operations. 

In some cases, UAS may eliminate the use of helicopters or small aircraft to 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 

of the project site as well as surrounding areas. Reliance of helicopters or small aircraft may be 

eliminated; 

4. Aerial surveying. The use of UAS in connection with aerial surveying of smaller areas may 

eliminate the use of helicopters or aircraft. 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 or viewable with 

helicopters and aircraft. UAS may be implemented quicker as time is of the essence during 

search and rescue operations. 

Petition for 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 aircraft for the following reasons: 

1. The UAS will weigh less than ten (10) pounds; 

2. Flights will be operated within the visual line of sight of the 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 at an altitude of 200 feet AGL. Flights will never exceed 400 feet AGL; 

5. Minimum crew for each operation will consist of the UAS pilot and a Visual 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 of all persons within 100 feet of flight operation; 

8. Written and/or oral permission from relative property owners will be obtained prior to operating the 

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 move vertically and 

horizontally; 

12. The UAS will have the capability to return and land at the pre-determined location with the Security 

Perimeter should the UAS lose communication or GPS signal during any operations; 

13. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies; 

14. Operations will not be conducted over densely populated areas or heavily traffic highways; and 

15. Operations will not be conducted within five (5) NM of an airport or 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 of marks; 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 aircraft flight manual, marking and placard requirements; 

6. 14 C.F.R. 91.109 Flight instruction; Simulated instrument flight and certain flight tests; 

7. 14 C.F.R. 91.119Minimum safe altitudes: general; 

8. 14 C.F.R. 91.121 Altimeter settings; 

9. 14 C.F.R. 91.151 Fuel requirements for flight in VFR conditions; 

10. 14 C.F.R. 91.203 Civil aircraft: Certifications required; 

11. 14 C.F.R. 91.205 Powered civil aircraft with standard category U.S. airworthiness certificates: 

Instrument and equipment requirements; 

12.14 C.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. 14 C.F.R. 91.407 Operation after maintenance, preventive maintenance, rebuilding or alteration; 

17. 14 C.F.R. 91.409 Inspections; 

Petition for FAA Section 333 Exemption Page 3 
18. 14 C.F.R. 91.411 Altimeter system and altitude reporting equipment tests 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 a technical 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 a Solution Engineer and UAS aviation advisor for 

a large Energy company. Richard also has several hours of flying experience in UAS platforms. 

Larry C. Clever- Chief Pilot and UAS Operations Manager. Former military (Air Force) pilot and is a flight 

instructor certificated by the FFA as a Commercial pilot, CFII, with Single and Multiengine, Instrument, 

ratings and a Gold Seal endorsement. He has accumulated over 10,000 hours of total flight time as an 

instructor and commercial pilot. In addition, he holds an MBA in Information Technology Management. 

Larry also has several hours of flying experience in UAS platforms. 

Proposed UAS Platforms for WTI Flight Operations: 

1. Yuneec Q500 4K 

2. Yuneec Tornado H920 

3. DJI Spread Wings S1000+ 

4. 3DRSOLO 

Petition for FAA Section 333 Exemption Page4 
UAS Platforms Specifications: 

Yuneec QSOO 4K 

Typhoon Aucraft 

Dimension 

f2 2~~~~ ... ··.· ' . . 

~I' 'ill;; 

. . / 

330mm / (U.oln) 

Right Tune up to 2 5 minutes 

Weight with Battery and Payload 60.0 oz (1700g) 

Weight without Battery and 40.0 oz (11 30g) Payload 

Battery 5400mAh 35 II .IV LiPo (included) 

4lOmm 

(16.Sin) 

210mm 

(8.llnJ 

Charger 3S 11.1 v UPo DC Balancing smart Charger with AC 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) 

MaXImum Rotation Rate 65 '/s 

MaXimum Roll Angle 35' 

Operating Temperature Range -s·c to so·c 

Radio Control FrequeiK'( Band 2.4GHz 

MaX. Descent Speed 2mrs 

MaX. Flight Speed 8m/s 

Petition for FAA Section 333 Exemption Page 5 
Personal Ground Stat1on 

Dimensions 

Type 

Operating System 

Number of Channels 

Control Transmission Range 

(Optimum Conditions) 

Robust Radio Control Modulation 

Video Unk Frequency Sand 

Video Transmission Range 

(Optimum Conditions) 

Flight Systems Telemetry oata 

On Screen Display 

LED Baddit LCD Screen 

Tactile (Vibrating) and Audible 

Feedback 

Built-in UPo Sanery Voltage 1 

capacity 

Screen Resolution 

camera Settings 

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 of Sight of Aircraft 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 of Sight of Aircraft 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 6 
Yuneec Tornado H920 

vunc.c.C 

Ei..EC:Tii;IC A\'l.t'l.T;O~ 

AightTime 

Dimension 

Diagonal Length Without Rotor Blades 

Propeller/Main Rotor Diameter 

Weight with GB603, GH4 camera and Banery 

Banery 

Charger 

Transmitter 

4 Right Modes 

MaXimum Flying Height(Absolute altirude) 

MaXimum Aying Height( Relative altirude) 

MaXimum Rotation Rate 

MaXimum Roll Angle 

Maximum Horizontal Speed 

Radio Control Frequency Band 

Operating Temperawre Range 

Petition for FAA Section 333 Exemption Page 7 
DJI Spread Wings 51000+ 

Frame 

Motor 

ESC 

Foldable Propeller 

(1552/1552R) 

Frame Amll""G'h 

Center Frame Weight !'MIIll..anding Gear -ng Ba!se. 

servos> 

ICV 

--

WEighllwilh Cooling Fan! 

Petition for FAA Section 333 Exemption 

!OC.Srrm 

3l5g 

5!)(M' 

35g 

Page 8 
Flight Parameters !I 

To!al Weigh!: 

Hover Pt)'M"f Consumption 

Hover Time 

Gain Value Setnngs 

For Worol<onJ;;M Flight C011!Jullt'f 

Petition for FAA Section 333 Exemption Page 9 
3DRSOLO 

Specs: 

Cameras: Compatible with GoPro® HER03, 3+ and 4; optimized for HERQ3.,. and 4 

Streaming video quality: 720p 

Right time: 25 minutes; 20 minutes with payload" 

Range: .5 miles- (.8 km) 

Max speed: 55 mph (89 km/h) 

Max ascent speed: 10 m/s in stabilize mode; 5 m/s in "ffy'' mode 

Max descent speed: ditto 

Max payload: 420 g 

Max altitude: 400ft per FAA regulation, user adjustable {122m) 

Motors: 880 kV 

Propellers: 1 0" diameter 4.5" pitch self-tightening (24 em diameter 144 em pitch); glass-reinforced nylon 

Autopilot: Pixhawk 2 

Software: APM:Copter 

Communication: 3DR Link secure WiFi network 

Frequency: 2.4 GHz 

Weight: 3.3 lbs. (1.5 kg) J 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal 

Dimensions: 10 in. taU (25 ern), 18 in. (46 em) motor-to-motor 

Right batte<y: Lithium polymer 5200 mAh 14.8 Vdc 

Battery charge time: -1.5 hours 

Controller batte<y: 2600 mAh 7.2 Vdc rechargeable lithium ion 

App requirements: .OS 8.0 or later I Android 4.3 or later 

*Flight time varies with payload, wind conditions, elevation, temperature, humidity, flying style and pilot skiD. Listed flight time applies to elevations 

less than 2,000 ft above sea level. 

**Depending on environmental conditions; controller is expandable, aUowing us or third parties to amp up the range in the future. 

Solo Sman Battery: 

Rechargeable lithium polymer (U-Po) 

5200mAh 

14.8Vdc 

Weight: 1 lb (.5 kg) 

Solo Gimbal: 

Three-axis stab~ization 

Fully compatible with 3DR Solo and GoPro HER03 ... and HER04; camera charging and stabilization only with HEROS 

HDMI video output 

Wireless software upgrade through Solo 

Controllable range: o• to -oo· pitch 

Petition for FAA Section 333 Exemption Page 10 
I respectfully submit this Petition for FAA Section 333 exemption. Please feel free to contact d should 

you have any additional questions or comments. 

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