1 

October 1, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Amendment to Exemption No. 12783 in Regulatory Docket No. FAA–2015–1586 

Issued Under Section 333 of the FMRA and Part 11 of the Federal Aviation 

Regulations 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“FMRA”) and 14 

C.F.R. Part 11, Qualcomm Technologies, Inc. (“Qualcomm” or “Petitioner”) hereby seeks an 

amendment to Exemption No. 12783 to operate an additional small Unmanned Aircraft System 

(“UAS”): the Qualcomm 210qc. On September 8, 2015, the FAA issued Exemption No. 12783 

to Qualcomm to allow it to operate the DJI Flamewheel 450 to conduct research and 

development. This requested amendment to that exemption will allow Qualcomm to operate the 

210qc for the same purpose and under the same conditions as in Exemption No. 12783. 

The 210qc platform is a small UAS, measuring 210mm (diagonal) and having a 240g airframe. 

This platform is much smaller and significantly lighter than the DJI Flamewheel 450 used in 

Qualcomm’s initial Section 333 petition. The 210qc will be operated under controlled conditions 

and at low altitudes in airspace that is limited in scope. The 210qc includes safety features such 

as geo-fencing capabilities, programmed fail safe configurations, and lost transmitter link 

protocols. Qualcomm will comply with all of the conditions and limitations imposed by 

Exemption 12783 and will ensure at least an equivalent level of safety to currently authorized 

operations using manned aircraft. More details of the 210qc’s safety features and operating 

procedures are provided in Qualcomm’s UAS Operations Manual, which Qualcomm submits to 

the FAA via email and with a request for confidential treatment. 

The name and address of the applicant are: 

Qualcomm Technologies, Inc. 

Paul Guckian 

Vice President, Engineering 

5775 Morehouse Drive 

San Diego, CA 92121 

pguckian@qualcomm.com 

(858) 651-1547 
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Qualcomm respectfully requests exemption from the following regulatory provisions previously 

granted by the FAA in Exemption No. 12783.1

14 C.F.R. §§ 61.23(a) and (c); 

14 C.F.R. §§ 61.101(e)(4) and (5); 

14 C.F.R. §§ 61.113(a); 

14 C.F.R. § 61.315(a); 

14 C.F.R. § 91.7(a); 

14 C.F.R. § 91.119(c); 

14 C.F.R. § 91.121; 

14 C.F.R. § 91.151(a)(1); 

14 C.F.R. § 91.405(a); 

14 C.F.R. § 91.407(a)(1); 

14 C.F.R. §§ 91.409(a)(1) and (2); 

14 C.F.R. §§ 91.417(a) and (b). 

Good cause exists to grant Qualcomm an amendment to Exemption No. 12783. Doing so is in 

the public interest based on the criteria provided in Section 333 of the FMRA regarding size, 

weight, speed, operating capabilities, proximity to airports and populated areas, operation within 

visual line of sight, and national security. Qualcomm requests summary grant of this amendment 

because the FAA has granted previous exemptions for operation of UAS for research and 

development that are similar in all material respects to this amendment.2

Please do not hesitate to contact Qualcomm’s outside counsel, R. Michael Senkowski at 202-

719-7249 or msenkowski@wileyrein.com, Katy Ross at 202-719-7410 or 

kmross@wileyrein.com, and Gary Michel at 202-719-7252 or gmichel@wileyrein.com, with any 

questions about this filing. 

 Sincerely, 

/s/ Dean R. Brenner 

 Dean R. Brenner 

 Senior Vice President, 

 Government Affairs 

 Qualcomm Technologies, Inc. 

 

 

1

 Qualcomm will operate under the same operating conditions as those required under the original grant of 

exemption (No. 12783), in which exemptions for certain FARs was deemed by the FAA as “not necessary.” 

Accordingly, Qualcomm does not request FAA exemption from 14 C.F.R. Part 21, Subpart H. 

2

 See, e.g., Exemption Nos. 12783 to Qualcomm Technologies, Inc. (see Docket No. FAA-2015-1586), 

111311 to Next Generation Aviation Services, L.L.C. (see Docket No. FAA-2014-1055), 11315 to The Climate 

Corporation and Precision Planting, LLC (see Docket No. FAA-2014-1037), and 11290 to Amazon.com (see Docket 

No. FAA-2014-0474). 
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Attachment: Confidential Operations Manual submitted via email to 333exemptions@faa.gov