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 Moderniza tion and Reform Act of 2012 (“FMRA”) and 14 C.F.R. Part 11, Qualcomm Technologies, Inc. (“Qu alcomm” 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 th at is limited in scope. The 210qc includes safety features such as geo-fencing capabilities, programmed fail sa fe 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 detail s of the 210qc’s safety features and operating procedures are provided in Qualcomm’s UAS Op erations 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) 651-15472 Qualcomm respectfully requests exemption from th e 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 S ection 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 su mmary grant of this amendment because the FAA has granted previous exemp tions 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.co m, 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 exemp tions 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).3 Attachment: Confidential Operations Manual submitted via email to 333exemptions@faa.gov